A business league exempt under Code section 501(c)(6) organization is a membership organization characteristically supported by dues. Although an organization may receive a substantial portion or even the primary part of its income from non-member sources, membership support, either in the form of dues paid to or involvement in the organization's activities, must be meaningful.

For this purpose, membership support includes the following items:

• Amounts derived from performing the organization's exempt functions or from substantially related activities
• Contributions or gifts from the general public

Unrelated income is excluded in measuring the extent of membership support. Thus, for example, dues from associate members are generally not considered.

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