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Exempt Organizations Revenue Rulings

2016

 

None available during this period.

 


 

2015

 

None available during this period.

 


 

2014

 

None available during this period.

 


 

2013

 

None available during this period.

 


 

2012

 

None available during this period.

 


 

2011

 

Revenue Ruling 2011-7: Clarifying how the section 403(b) plan termination provisions apply.

 


 

2010

 

Revenue Ruling 2010-13: Publishing average premium for small group market, for determining the small employer health insurance credit under section 45R of the Internal Revenue Code.

 


 

2009

 

None available during this period.

 


 

2008

 

None available during this period.

 


 

2007

 

Revenue Ruling 2007-41: Guidelines on the scope of the tax law prohibition of political campaign activities by section 501(c)(3) tax-exempt organizations.

 


 

2006

 

Revenue Ruling 2006-27: Seller-funded down-payment assistance to home buyers provides private benefit to sellers and does not further exclusively charitable purposes.

 


 

2005

 

None available during this period.

 


 

2004

 

Revenue Ruling 2004-112: Whether Internet activities conducted by an exempt trade association are within the specific exception for qualified convention and trade show activity under Internal Revenue Code section 513(d)(3)(B).

Revenue Ruling 2004-51: Whether a university continues to qualify for exemption under Internal Revenue Code section 501(c)(3), or receives unrelated business taxable income, where it contributes part of its assets to, and conducts a portion of its activities through, a limited liability company formed with a for-profit corporation.

Revenue Ruling 2004-6: Clarifying the tax implications under Code section 527(f) of political activities by section 501(c)(4) social welfare organizations, 501(c)(5) labor and agricultural/horticultural organizations, and 501(c)(6) business leagues.

 


 

2003

 

Revenue Ruling 2003-64: In computing unrelated business income tax, an exempt social club may claim the credit under Code section 45B for the portion of employer social security taxes paid with respect to employee tips received from both members and nonmembers.

Revenue Ruling 2003-49: Questions and answers regarding the reporting and disclosure requirements for Code section 527. This ruling modifies and supersedes Revenue Ruling 2000-49, 2000-44 I.R.B. 430.

Revenue Ruling 2003-32: Scholarships and educational grants awarded by a private foundation under an employer-related program to employees and their children are not compensation to the employee when the employee is killed or seriously injured in a qualified disaster. Thus, grants under the program satisfy the requirements of section 4945(g) and are not taxable expenditures under Code section 4945(d)(3).

Revenue Ruling 2003-28: Circumstances under which a taxpayer's contribution to a qualified charity of interests in a patent is deductible as a charitable contribution under Code section 170.

Revenue Ruling 2003-13: Describing the responsibilities of private foundations that distribute all of their net assets to one or more public charities described in Internal Revenue Code section 509(a)(1), 509(a)(2), or 509(a)(3).

Revenue Ruling 2003-12: Guidance on dissolution provisions for any section 501(c)(3) organization that requests a letter ruling that its income is excluded from gross income under Code section 115(1).

 


 

2002

 

Revenue Ruling 2002-67: Tax consequences under Internal Revenue Code section 170 (relating to the income tax charitable deduction) of a taxpayer's transfer of a used car to an authorized agent of a charity.

Revenue Ruling 2002-55: A cooperative exempt from federal income tax under Code section 501(c)(12) is not required to include income of its subsidiary for purposes of calculating the 85 percent member income test of section 501(c)(12)(A).

Revenue Ruling 2002-54: Tax consequences of a section 501(c)(12) exempt electric cooperative distributing and selling propane in tanks to its members.

Revenue Ruling 2002-28: Tax consequences to a private foundation of transferring all of its assets to another private foundation.

 


 

2001

 

None available during this period.

 


 

2000

 

Revenue Ruling 2000-49: Questions and answers about the notice and reporting requirements of section 527 of the Internal Revenue Code (modified and superseded by Revenue Ruling 2003-49).

 


 

1999

 

None available during this period.

 


 

1998

 

Revenue Ruling 98-15:  Whether an exempt health care organization that transfers substantially all of its assets to a for-profit entity, which thereafter operates the acute care hospital formerly operated by the organization, continues to qualify for exemption under Code section 501(c)(3).

 


 

1997

 

Revenue Ruling 97-21: Tax consequences of physician recruitment incentives provided by hospitals described in Code section 501(c)(3).

 


 

1996

 

Revenue Ruling 96-11: Discussing tax consequences of a charitable contribution by a partnership.

 


 

1995

 

Revenue Ruling 95-8: Income an exempt organization receives that is attributable to a short sale of publicly traded stock through a broker is not treated as unrelated debt-financed income under Code section 514.

 


 

1994

 

Revenue Ruling 94-16: Federal income taxation of Indian tribes and corporations owned by Indian tribes.

 


 

1993

 

None available during this period.

 


 

1992

 

None available during this period.

 


 

1991

 

None available during this period.

 


 

1990

 

Revenue Ruling 90-100: Guidance relating to notice requirements under Internal Revenue Code section 508, for filing applications for recognition of exemption under section 501(c)(3).

 


 

1989

 

Revenue Ruling 89-94: Relieving federal credit unions from filing Form 990 because they are described in Code section 501(c)(1).

 


 

1988

 

None available during this period.

 


 

1987

 

Revenue Ruling 87-126: A nonprofit association that provides firefighters with retirement benefits, which are funded by government sources and are the exclusive retirement funds provided to these firefighters, qualifies for exemption as a social welfare organization described in Code section 501(c)(4).

Revenue Ruling 87-119: Questions and answers about the income tax treatment of certain expenditures of campaign funds, including treatment to the campaign or fund under Code section 527.

Revenue Ruling 87-73: When section 38 property is sold to a tax-exempt organization and, as part of the same transaction, leased back to the seller, investment credit recapture under Code section 47 is required unless the organization uses the property predominantly in an unrelated trade or business, income from which is subject to tax under section 511.

Revenue Ruling 87-2: A lawyer trust account fund created, supervised, and controlled by a state supreme court is not subject to federal income tax; interest income earned on pooled accounts is not included in gross income of either the clients or the lawyers.

 


 

1986

 

Revenue Ruling 86-98: An individual practice association that provides health services through written agreements with health maintenance organizations does not qualify for exemption as a social welfare organization under Code section 501(c)(4) or as a business league under section 501(c)(6).

Revenue Ruling 86-95: Conduct of public forums involving qualified congressional candidates, the manner described in the ruling, by an organization otherwise exempt under Code section 501(c)(3), will not constitute participation or intervention in a political campaign.

Revenue Ruling 86-90: Grants awarded by a private foundation under an employer-related program are scholarships under Code section 117(a), even though the grants will be awarded without regard to the percentage guidelines of Rev. Proc. 76-47, sec. 4.08. Thus, the grants will not be taxable expenditures under section 4945.

Revenue Ruling 86-77: Private foundation that made grants to individuals after 45 days from the date it submitted an exemption application, under procedures fully disclosed in its application, did not make taxable expenditures under Code section 4945, even though the foundation did not specifically request advance approval of its procedures.

Revenue Ruling 86-75: Whole life insurance is a life benefit under Code section 501(c)(8) even though the policies contain investment features such as cash surrender value and policy loan.

Revenue Ruling 86-53: Sale by a private foundation of stock owned continuously since May 26, 1969, but not constituting excess business holdings on that date, is excepted from the prohibition on self-dealing in Code section 4941.

Revenue Ruling 86-49: An organization formed to preserve the historic or architectural character of a community by acquiring, restoring, and sometimes disposing of properties, may qualify for exemption under Code section 501(c)(3).

 


 

1985

 

Revenue Ruling 85-199: A trust created to provide sick, accident, and other benefits to only one employee does not qualify for exemption under Code section 501(c)(9).

Revenue Ruling 85-184: Utility customers who pay additional amounts on their bills to a utility company acting as an agent for a charitable organization that assists individuals with emergency energy needs, are entitled to a charitable deduction for the additional amount in the year paid.

Revenue Ruling 85-173: An organization that has no gross receipts in its first two taxable years, but receives more than $15,000 in contributions from the general public in its third year, meets the notice requirement of Code section 508(a) if it files for recognition of exemption under section 501(c)(3) within 90 days after the close of its third taxable year.  It will be recognized as exempt as of the date it was created.

Revenue Ruling 85-162: A loan program of a private foundation that provides loan financing to publicly supported organizations for construction projects in disadvantaged areas does not result in self-dealing under Code section 4941 merely because certain individuals involved in the construction projects have ordinary banking and business relationships with a bank that is a disqualified person.

Revenue Ruling 85-160: Provisions in an organization's governing instrument that satisfy the requirements of Code section 508(e) (regarding qualification for exemption under section 501(c) as a private foundation) are not in themselves sufficient to meet the requirements of section 1.501(c)(3)-1(b)(4) of the Income Tax Regulations that, upon dissolution, the organization's assets be dedicated to an exempt purpose.

Revenue Ruling 85-123: Certain revenue rulings holding that income from the rental of booth space at a show or convention are revoked; certain rulings that imply that selling activity at a trade show would result in unrelated trade or business are obsoleted.

Revenue Ruling 85-115: State income taxes paid by a political organization on its non-exempt function income are deductible in computing its taxable income under Code section 527(c).

Revenue Ruling 85-110: Performance of diagnostic laboratory testing on referred specimens from private patients of hospital staff physicians, by a hospital exempt under Code section 501(c)(3), is unrelated trade or business if such services are otherwise available in the community.

Revenue Ruling 85-109: The IRS will not follow that portion of the decision in St. Luke's Hospital of Kansas City v. United States that held that a tax-exempt hospital's performance of laboratory testing upon referred specimens from private patients of the hospital's staff physicians is not unrelated trade or business because the services were not performance for the convenience of the hospital's members.

Revenue Ruling 85-2: An organization that provides legal assistance to guardians ad litem who represent abused and neglected children before a juvenile court that requires their appointment lessens the burdens of government and therefore qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 85-1: An organization that provides funds to a county's law enforcement agencies to police illegal narcotic traffic lessens the burdens of government, a recognized charitable purpose, and qualifies for exemption under Code section 501(c)(3).

 


 

1984

 

Revenue Ruling 84-169: Tax imposed under Code section 4940(a) is an excise tax and not an income tax; unless an income tax treaty provides otherwise, excises taxes in general or the section 4940(a) tax in particular will not be treated as a covered tax under that United States income tax treaty.

Revenue Ruling 84-140: Contributions to an organization, 90 percent of the membership of which is composed of war veterans of the Armed Forces of the United States, are deductible under Code section 170(c)(3); the fact that a small percentage of members have not served in a branch of the Armed Forces will not prevent the organization from being classified as a war veterans organization.

Revenue Ruling 84-49: A fraternal beneficiary society that operates an orphanage for surviving children of deceased members provides other benefits within the meaning of Code section 501(c)(8).

 


 

1983

 

Revenue Ruling 83-170: A cooperative organization furnishing cable television service to its members qualifies for exemption from federal income tax as a like organization within the meaning of Code section 501(c)(12) (modifying Revenue Ruling 55-716).

Revenue Ruling 83-166: An organization created after August 31, 1957, for the purpose of insuring individuals' deposits in state-chartered credit unions, does not qualify for exemption under either section 501(c)(6) or section 501(c)(14)(B) of the Code.

Revenue Ruling 83-164: An organization whose members represent diverse businesses that own, rent, or lease computers produced by a single computer manufacturer does not qualify for exemption as a business league under Code section 501(c)(6) (distinguishing Revenue Ruling 74-147).

Revenue Ruling 83-157: A nonprofit hospital that is not required to operate an emergency room where a state or local health planning agency has found that this would unnecessarily duplicate emergency services and facilities that are adequately provided by another medical institution in the community is exempt under Code section 501(c)(3) (amplifying Revenue Ruling 69-545).

Revenue Ruling 83-153: Medicare and Medicaid payments are gross receipts derived from the exercise or performance of a health care organization's exempt activities for purposes of the support test of Code sections 170(b)(1)(A)(vi) and 509(a)(2).

Revenue Ruling 83-140: Nonprofit corporation that operates a wilderness camping program to rehabilitate and provide counseling to adolescents who have emotional and behavioral problems is a nonprofit educational organization for specified purposes under the Internal Revenue Code.

Revenue Ruling 83-104: Factual situations illustrate the distinction between qualified charitable contributions and tuition payments made to an organization that operates a private school (superseding Revenue Ruling 73-99).

Revenue Ruling 83-43: A benevolent life association that does not terminate membership when a member moves from the local area in which the association operates is of a purely local character and may qualify for exemption under Code section 501(c)(12).

Revenue Ruling 83-19: Investment by a university, as trustee, of the assets of charitable remainder trusts in its general endowment investment fund will not jeopardize the exempt status of the charitable remainder trusts or donors' charitable contribution deductions (amplifying Revenue Ruling 73-571).

 


 

1982

 

Revenue Ruling 82-223: Discussing the treatment, under sections 4941(d)(1)(E) and 4945(d)(5), of indemnification amounts and of insurance premiums paid by a private foundation to or on behalf of a foundation manager who is a defendant ion a proceeding involving state laws relating to the mismanagement of funds of charitable organizations.

Revenue Ruling 82-218: Property used predominantly in an unrelated trade or business of a college or university that is both an instrumentality of a state and an organization exempt from tax under Code section 501(c)(3) is not excluded from the definition of section 38 property, when the income from the unrelated trade or business is subject to tax under section 511.

Revenue Ruling 82-216: The Service will no longer contend that contributions to or on behalf of a political organization described in Code section 527(e) are transfers subject to the gift tax, irrespective of when the transfers were made.

Revenue Ruling 82-148: Obsoleting certain revenue rulings relating to voluntary employee beneficiary associations under Code section 501(c)(9), due to changes in the governing regulatory provisions.

Revenue Ruling 82-139: Publishing ordinary commercial advertising for products and services used by the legal profession in a bar association's journal is unrelated trade or business under Code section 513; but publishing legal notices is not unrelated trade or business.

Revenue Ruling 82-138: A trust created pursuant to collective bargaining agreements between a labor union and several business leagues, to monitor and coordinate business league activities of its member business leagues and collecting, administering, and disbursing funds to the member leagues for business league purposes, is exempt as a business league under Code section 501(c)(6).

Revenue Ruling 82-137: In determining a foundation's minimum investment return under Code section 4942, the percentage of exempt use of a building used by a private foundation partly to carry out its exempt purposes and partly for commercial leasing, should be determined by dividing the fair rental of that portion of the building used for exempt purposes by the fair rental value of the entire building.

Revenue Ruling 82-136: A grant by a private foundation to a second private foundation is not an act of self-dealing within the meaning of Code section 4941, even though a banking institution serves as sole trustee of both foundations.

Revenue Ruling 82-132: The substantial support tests in Code section 170(b)(1)(A)(vi) also apply to allow an organization organized and operated for the benefit of a state university, otherwise described in section 170(b)(1)(A)(iv), to meet the substantial support test of that section, provided that the organization's sources of support do not include support from sources permitted by section 170(b)(1)(A)(vi), but not permitted by section 170(b)(1)(A)(iv).

 


 

1981

 

Revenue Ruling 81-293: The payment of compensation to research assistants by an individual grantee of a private foundation, where the grantee controls the selection of these persons independently of the grantor foundation and where the foundation's grant-making procedures satisfy the requirements of Code section 4945(g), doe snot constitute a grant to an individual within the meaning of section 4945(d)(3).

Revenue Ruling 81-291: For taxable years of a mutual or cooperative telephone company beginning after 1974, the 85 percent member-income test for exemption under Code section 501(c)(12) is applied without taking into account income received or accrued from another telephone company for the performance of communication services involving the completion of long distance calls to, from, or between members of the mutual or cooperative telephone company.

Revenue Ruling 81-284: A nonprofit small business investment company licensed under section 301(d) of the Small Business Investment Act of 1958, which was formed to relieve poverty, eliminate prejudice and discrimination, reduce neighborhood tensions, and combat community deterioration, and that provides low-cost or long-term loans to business not able to obtain funds from conventional commercial sources, with preference given to businesses that provide training and employment opportunities for the  unemployed or under-employed residents of economically depressed areas, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 81-276: A professional standards review organization qualifies for exemption under Code section 501(c)(3) and is not a private foundation because it is publicly supported within the meaning of section 170(b)(1)(A)(vi).

Revenue Ruling 81-217: A private foundation that pays grants to an organization that is not a private foundation to provide scholarships only to children of a particular employer is making grants to individuals for which advance approval under Code section 4945(g)(1) is required, and employer-related grants to which the guidelines in Revenue Procedure 76-47 apply.

Revenue Ruling 81-178: Payments an exempt labor organization receives from various business enterprises to use the organization's trademark and similar properties are non-taxable royalties under Code section 512(b)(2), but payments for personal appearances by the organization's members are taxable payments for services.

Revenue Ruling 81-177: Application of the exception in Code section 508(c)(1)(B) to the requirement for filing notice of exempt status under Code section 501(c)(3).

Revenue Ruling 81-175: A nonprofit association of insurance companies that accepts for reinsurance high-risk customers who would ordinarily be turned down by member companies is not exempt under Code section 501(c)(6) as a business league.

Revenue Ruling 81-174: A nonprofit association of insurance companies that provides medical malpractice insurance to health care providers is not exempt under Code section 501(c)(6) as a business league.

Revenue Ruling 81-138: An exempt organization created by a chamber of commerce to encourage business development in a particular area obtained a mortgage to help finance the construction of a building leased to an industry tenant at less than fair rental value. The leasing of the property is substantially related to the organization's exempt purposes and the property is not debt-financed property.

Revenue Ruling 81-127: The certification of export documents by a chamber of commerce exempt from federal income tax under Code section 501(c)(6), is not, under the circumstances described in the ruling, an unrelated trade or business within the meaning of section 513.

Revenue Ruling 81-125: A grant for exclusively charitable purposes made by a private foundation to a wholly owned instrumentality of a political subdivision of a state, is not a taxable expenditure under Code section 4945(d)(4), even if the foundation does not exercise expenditure responsibility over the grant.

Revenue Ruling 81-119: An interest in a business enterprise acquired by a private foundation under the terms of a will, executed under the circumstances described in the ruling, is within the provisions of Code sections 4943(c)(4) and (c)(5), and therefore treated as if it were held by a private foundation on May 26, 1969 (and "grandfathered" for certain purposes).

Revenue Ruling 81-117: An organization that does not conduct any fraternal activities or operate under the lodge system, but does operate exclusively for the benefit of members of certain related domestic fraternal societies operating under the lodge system, does not qualify for exemption under Code section 501(c)(10).

Revenue Ruling 81-116: An organization that provides and maintains free off-street parking to anyone visiting a city's downtown business district qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 81-111: For purposes of computing the 35 percent permitted holdings rule of Code section 4943(c)(2)(B), effective control in one or more persons may be demonstrated by proving that some unrelated party or cohesive group of third parties, in fact exercises control over the business enterprise. It is not enough to show that the private foundation and disqualified persons cannot exercise such control.

Revenue Ruling 81-109: A mutual ditch company that operates in a traditional manner consistent with the provisions of a particular state statute may qualify for exemption under Code section 501(c)(12), even though it does not satisfy all of the requirements of Revenue Ruling 72-36.

Revenue Ruling 81-108: A corporation that holds a leasehold interest in an office building, derives all its income from subleasing space in the building to the general public, and turns over the net rents to its exempt parent, qualifies for exemption under Code section 501(c)(2).

Revenue Ruling 81-101: In computing the amount of unrelated business taxable income from advertising in an exempt organization's periodical, the proper method of allocating membership receipts to circulation income under the formula in section 1.512(a)-1(f)(4)(iii) of the Income Tax Regulations.

Revenue Ruling 81-95: Where an exempt organization's primary activities promote social welfare, its lawful participation or intervention in political campaigns on behalf of or in opposition to candidates for public office will not adverse affect its exempt status under Code section 501(c)(4). The organization will, however, be subject to the tax imposed by section 527 on any of its expenditures for political activities that come within the meaning of section 527(e)(2).

Revenue Ruling 81-94: A "church" formed by a professional nurse (who is also the church's minister, director, and principal officer) and that is used primarily as a vehicle for handling the nurse's personal financial transactions, is not exempt from income tax under Code section 501(c)(3).

Revenue Ruling 81-76: Because an employee stock ownership trust is not treated as the owner of stock allocated to participating employees, it is not a disqualified person with respect to a private foundation created by the employer.

Revenue Ruling 81-75: A language translation service provided by an exempt trade association that promotes and develops trade relations between business entities located in the United States and the government of a foreign country is an unrelated trade or business under Code section 513.

Revenue Ruling 81-69: A section 501(c)(7) may not, in determining its unrelated business taxable income, reduce its net investment income by losses from sales to nonmembers where it has consistently sold food and beverages to nonmembers at prices insufficient to recover the cost of sales.

Revenue Ruling 81-68: A provision in a new collective bargaining agreement that calls for the termination of a supplemental unemployment benefit plan and the distribution of residuary assets to employees covered by the plan, will not affect the exempt status of a trust created to administer the plan, if the plan has been in effect long enough to satisfy the requirements of section 1.501(c)(17)-2(d) of the Income Tax Regulations, and satisfaction of all liabilities to employees is guaranteed.

Revenue Ruling 81-62: Sale of heavy-duty appliances to senior citizens by a senior citizens' center exempt under Code section 501(c)(3) is an unrelated trade or business.

Revenue Ruling 81-61: Operation of a beauty shop and a barber shop by a senior citizens' center exempt under Code section 501(c)(3), for use by senior citizens, is not an unrelated trade or business.

Revenue Ruling 81-59: A local association of farmers, formed to promote more effective agricultural pest control, that employs pest management scouts who periodically inspect members' fields, identify and count agricultural pests, and compile data on agricultural pest infestation, qualifies for exemption under Code section 501(c)(5).

Revenue Ruling 81-58: A nonprofit police officer association whose primary activity is providing retirement benefits to its members or death benefits to their beneficiaries will not qualify as an exempt section 501(c)(4) social welfare organization for taxable years beginning after August 23, 1981 (amplifying Revenue Ruling 75-199).

Revenue Ruling 81-46: Treatment of grants made by a private foundation after being notified by the Service that its grant-making program does not meet the requirements of Code section 4945(g).

Revenue Ruling 81-43: A community trust described in section 1.170A-9(e)(11) of the Income Tax Regulations, that was created by a community chest to hold permanently endowed charitable funds and to distribute income to support local charitable organizations that are public charities, is a supporting organization under Code section 509(a)(3) (and not a private foundation), even if the publicly supported organizations are not specified by name.

Revenue Ruling 81-40: A disqualified person's attempt to correct an act of self-dealing under Code section 4941(d)(1)(B) by transferring to a private foundation real estate, the fair market value of which equals the amount of a loan made by the foundation to the disqualified person, is a second act of self-dealing.

Revenue Ruling 81-29: A library computer network organization that provides bibliographic information to member libraries, some of which are not tax-exempt, qualifies for exemption under Code section 501(c)(3), where the computer system is operated for educational.purposes and not to accomplish routine administrative functions of the users.

Revenue Ruling 81-19: Operation of soft drink and food vending machines and laundromat facilities on campus by a section 501(c)(3) organization formed to assist a university, is not an unrelated trade or business under Code section 513.

 


 

1980

 

Revenue Ruling 80-316: Illustrating the meaning of the word purchasing as used in Code section 501(e)(1)(A), relating to cooperative hospital service organizations.

Revenue Ruling 80-310: Any benefit to a manufacturing corporation that is a disqualified person with respect to a private foundation, from the foundation's grant to a university to establish an educational program in manufacturing engineering, is incidental to the educational purposes furthered by the grant, and therefore the grant will not result in self-dealing under section 4941.

Revenue Ruling 80-309: By building and leasing a public hospital and related facilities to an exempt charitable association that operates the facilities, for an amount sufficient only to retire indebtedness and meet necessary operating expenses, an organization furthers the charitable purpose of promoting the health of the community and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 80-302: An organization that conducts genealogical activities primarily for members of a particular family does not qualify for exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 80-301: A nonprofit organization whose membership is open to all persons in a particular area and which provides instruction in genealogical research techniques is operated exclusively for educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 80-298: A university that leases its stadium and related facilities to a professional football team is engaged in an unrelated trade or business under Code section 513; because the university provides substantial services for the convenience of the lessee, the income is not excluded as rents from real property under section 512(b)(3).

Revenue Ruling 80-297: Illustrating the unrelated business income tax treatment of a school's furnishing its tennis facilities to third parties under various circumstances.

Revenue Ruling 80-296: Sale of broadcasting rights to an annual intercollegiate athletic event by an organization exempt from tax under Code section 501(c)(3) is not an unrelated trade or business for an organization affiliated with a school that participates in the event.

Revenue Ruling 80-295: The sale of exclusive broadcasting rights, under circumstances specified, is substantially related to the purpose constituting the basis for exemption under Code section 501(c)(3) of an amateur athletic organization, and therefore not an unrelated trade or business under Code section 513.

Revenue Ruling 80-294: A section 501(c)(6) organization will not adversely affect its exempt status if its primary source of support is from selling broadcasting rights to the sports tournaments it conducts.

Revenue Ruling 80-287: Circumstances under which a nonprofit lawyer referral service qualifies for exemption from federal income tax under Code section 501(c)(3) or section 501(c)(6).

Revenue Ruling 80-286: Circumstances under which an organization that operates an exchange program for children from the United States and a foreign country qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 80-282: Publishing a newsletter containing the voting congressional incumbents on selected issues,  by an organization otherwise described in Code section 501(c)(3), does not constitute participating or intervening in a political campaign within the meaning of Code section 501(c)(3), under the circumstances described.

Revenue Ruling 80-279: An organization that mediates international environmental disputes, under the circumstances described in the ruling, qualifies for exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 80-278: An organization that institutes and maintains environmental litigation under the circumstances described in the ruling operates exclusively for charitable purposes and qualifies for exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 80-275: A charitable contribution deduction is not allowed under Code section 170 for contributions to an eligible charitable donee for use in, or in connection with, attempts to influence legislation.

Revenue Ruling 80-259: Illustrating application of the rules under Code section 508 requiring organizations to give notice of a claim to status as an organization exempt under Code section 501(c)(3).

Revenue Ruling 80-215: A nonprofit organization that develops, promotes, and governs a sport for individuals under 18 years of age qualifies for exemption under Code section 501(c)(3), where it provides a recreational outlet for young people and thereby combats juvenile delinquency.

Revenue Ruling 80-207: An organization that makes distributions to a university is not a supporting organization under Code section 509(a)(3) if it is controlled by a disqualified person and the employees of the disqualified person.

Revenue Ruling 80-206: A nonprofit organization that promotes the legal rights of all tenants in a community and occasionally initiates litigation to contest the validity of legislation adversely affecting tenants may qualify for exemption under Code section 501(c)(4) as a social welfare organization.

Revenue Ruling 80-200: A nonprofit organization that arranges to place orphan children living in foreign countries with adoptive parents in the United States qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 80-133: A private foundation's payments of premiums on a life insurance policy and the interest on a loan secured by the policy are jeopardizing investments under Code section 4944, where the investment did not, under the circumstances, demonstrate that foundation managers exercised ordinary business care and prudence in providing for the financial needs of the foundation in carrying out its exempt purposes.

Revenue Ruling 80-132: Donation by a disqualified person to a private foundation of a life insurance policy, which is subject to an outstanding loan, is an act of self dealing under Code section 4941.

Revenue Ruling 80-130: A social club's payments to members to bring in new members to the club do not cause the club's net earnings to inure to the members so as to disqualify the club from exemption under Code section 501(c)(7), where the payments are reasonable compensation for the performing necessary administrative services.

Revenue Ruling 80-118: Interest income a private foundation derives upon redeeming Series E bonds received from an estate is included in computing gross income under Code section 4940(c)(2) where an increase in the value of the bonds is not income of an estate subsequently distributed to the foundation.

Revenue Ruling 80-114: An organization that operates a Christian Science health care facility under the circumstances described serves the charitable purpose of promoting health, and may be recognized as exempt under Code section 501(c)(3).

Revenue Ruling 80-113: An organization having no financial history and filing its notice under Code section 508(a) after the time specified in the regulations under that section may obtain an advance ruling treating it as a publicly supported organization under sections 170(b)(1)(A)(vi) and 509(a)(1) during an advance ruling period beginning on the date it becomes exempt from federal income tax under section 501(c)(3).

Revenue Ruling 80-108: An organization that otherwise qualifies for exemption under sections 501(c)(3) and 501(c)(4), and that did not file its application for exemption under section 501(c)(3) within the time frame specified under Reg. 1.508-1(a)(2)(i), may be recognized as exempt under section 501(c)(4) for the period during which the regulation precludes it from being exempt under section 501(c)(3).

Revenue Ruling 80-107: An organization open to individuals and institutions having a beneficial interest in shares of any public utility company in the state did not qualify for exemption under Code section 501(c)(4); the organization operated primarily for the benefit of its public utility company members, and not to promote the common good and general welfare of the community.

Revenue Ruling 80-103: Proceeds received by a political organization from sales of art reproductions are not exempt function income within the meaning of Code section 527(c).

Revenue Ruling 80-97: A private foundation's contribution to a section 501(c)(13) cemetery company, which is not for purposes described in section 170(c)(2)(B), is a taxable expenditure under Code section 4945, and not a qualifying distribution under section 4942.

Revenue Ruling 80-86: Whether a section 501(c)(12) electric cooperative jeopardizes its exempt status when it sells excess gas at cost to nonmembers.

Revenue Ruling 80-63: Whether certain activities will affect the exempt status under Code section 501(c)(4) of otherwise qualified homeowners' associations.

 


 

1979

 

Revenue Ruling 79-403: Residential treatment center for emotional disturbed children operates a school program that qualifies for the excise tax exemptions under Code sections 4041(g)(4), 4221(a)(5), and 4253(j).

Revenue Ruling 79-375: If a private foundation that has made a qualifying distribution equal to the purchase price of an asset donates the asset to a publicly supported charity, it will be allowed a second qualifying distribution to the extent that the fair market value of the asset on the date of contribution exceeds the amount of the first qualifying distribution under Code section 4942(g)(1).

Revenue Ruling 79-374: Rental of office space by a private foundation to a disqualified person engaged in business activities in the same general subject area as the foundation's research constitutes, under the circumstances described in the ruling, self-dealing under Code section 4941(d)(1)(C).

Revenue Ruling 79-370: Sale by a section 501(c)(6) organization of a membership directory that contributes importantly to achieving the organization's purpose and confers no private commercial benefit on any of the members, who are the directory's sole purchasers, is not unrelated trade or business within the meaning of Code section 513. Rev. Rul. 74-38 is distinguished.

Revenue Ruling 79-369: An otherwise qualifying organization created to develop and promote an appreciation of contemporary symphonic and chamber music by recording and selling, primarily to educational institutions, new works of unrecognized composers as well as neglected works of more established composers is exempt from tax under Code section 501(c)(3).

Revenue Ruling 79-365: For purposes of Code sections 117(a) and 4945(g)(1), a private foundation's scholarship program for children of deceased or retired employees of a particular company is an employer-related grant program to which the guidelines of Rev. Proc. 76-47 apply.

Revenue Ruling 79-361: The operation of a miniature golf course in a commercial manner by an organization exempt from tax under section 501(c)(3), whose purpose is to provide for the welfare of young people, constitutes unrelated trade or business under section 513.

Revenue Ruling 79-360: The operation of health club facilities in a commercial manner by an organization exempt from tax under Code section 501(c)(3), whose purpose is to provide for the welfare of young people, constitutes unrelated trade or business under section 513.

Revenue Ruling 79-359: An otherwise qualifying organization whose purpose is to provide traditional burial services that directly support and maintain basic tenets and beliefs of a religion regarding burial of its members is operated exclusively for charitable purposes and is exempt from tax under Code section 501(c)(3).

Revenue Ruling 79-358: An otherwise qualifying organization that makes a private hospital room available to patients who can benefit medically from a private room but cannot afford the expense is operated exclusively for charitable purposes and is exempt from tax under Code section 501(c)(3).

Revenue Ruling 79-349: Interest income earned by an exempt employees' trust from mortgage loans, which form a significant portion of the trusts' assets, do not enter into the computation of unrelated business taxable income under Code section 513, but service fee receipts earned in connection with such loans do enter into the computation.

Revenue Ruling 79-316: A nonprofit organization whose purpose is to prevent oil spills within a city port area and to develop a program for the containment and cleanup of liquid spills that do occur qualifies for exemption as a social welfare organization under Code section 501(c)(4), provided that its services are equally available to members and nonmembers and both members and nonmembers are charged on the same basis for the cleanup services rendered.

Revenue Ruling 79-227: Rules for remedial amendments of qualified retirement plans maintained by employers exempt from returns under Code section 6033.

Revenue Ruling 79-223: An irrevocable trust whose governing instrument provides for distribution of all ordinary income to charitable organizations described in Code section 170(c) by the close of the year following the year of receipt, addition of capital gains to corpus, and termination of the trust and distribution of corpus to the grantor no sooner than ten years and one month after its creation is allowed a deduction under section 642(c)(1) for amounts of gross income paid to the charitable organizations, except to the extent the trust has unrelated business income.

Revenue Ruling 79-222: The investment of an exempt employees' trust as a limited partner in a partnership carrying on an unrelated trade or business may result in unrelated business taxable income within the meaning of Code section 512.

Revenue Ruling 79-200: Method for a private foundation to use in computing the basis of delectable property for purposes of determining the cost depletion deduction used in determining net investment income under Code section 4940.

Revenue Ruling 79-145: The federal excise taxes on wagering apply to a "Calcutta" that is operated in connection with a sports event by a nonprofit social club that allows members of similar social clubs to attend the events and uses a portion of entrance fees and wagers to help defray the expenses of operating the events.

Revenue Ruling 79-131: A private foundation that was created and funded by a for-profit company and that grants scholarships, based on objective standards, for the education of children of a particular community, regardless of whether the parents are employed by the company, is not operating an employer-related grant program subject to the guidelines of Rev. Proc. 76-47.

Revenue Ruling 79-130: Sales of taxable fuel and articles and communications services to a nonprofit corporation for its use in connection with regularly scheduled Yoga courses that are characterized by a regular faculty and curriculum and a regularly enrolled student body come within the excise tax exemption provided by Code sections 4041(g)(4), 4221(a)(5), and 4253(j).

Revenue Ruling 79-128: A nonprofit organization whose membership is limited to the employees of an employer in a particular municipality and whose primary purpose is to obtain for its members discount prices on merchandise, services, and activities, is not exempt as a local association of employees under Code section 501(c)(4).

Revenue Ruling 79-122: Employer securities purchased by a pension plan qualified under Code section 401(a) are not debt-financed property under section 514, and dividends and interest earned on such securities are not unrelated business taxable income to the trust.

Revenue Ruling 79-81: Amounts paid to an exempt religious organization by sponsors, who are solicited by individual members of a work-study program that includes attendance at the organization's theological college, to pay the approximate cost of the individual's tuition, room, and board at the college are not deductible under Code section 170.

Revenue Ruling 79-31: The operation of a fringe parking lot and shuttle bus service by an organization exempt from tax under Code section 501(c)(6) whose primary purpose is to retain and stimulate trade in a city's downtown area is not an unrelated trade or business within the meaning of Code section 513; but the organization's operation of a park and shop plan in which patrons of member merchants receive stamps entitling them to free parking is an unrelated trade or business.

Revenue Ruling 79-26: A nonprofit organization that provides information to the public about the public's right of access to the broadcast media and objectively evaluates the performance of local broadcasters in fulfilling their public service obligations is operated exclusively for charitable and educational purposes.

Revenue Ruling 79-19: A nonprofit organization that provides specially designed housing to physically handicapped persons at the lowest feasible cost and maintains in residence those tenants who subsequently become unable to pay its monthly fees is operated exclusively for charitable purposes within the meaning of Code section 501(c)(3).

Revenue Ruling 79-18: A nonprofit organization that provides specially designed housing to elderly persons at the lowest feasible cost and maintains in residence those tenants who subsequently become unable to pay its monthly fees, is an organization operated exclusively for charitable purposes within the meaning of Code section 501(c)(3).

Revenue Ruling 79-17: A nonprofit hospice, operated on both an inpatient and outpatient basis to alleviate the physical and mental distress of the terminally ill, is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 79-13: Amounts expended for voter research, public opinion polls, and voter canvasses on behalf of an elected legislator who becomes a candidate for another political office, which are paid from surplus funds from an earlier campaign maintained in a separate bank account qualifying as a political organization under Code section 527, are not includible in the legislator's gross income.

Revenue Ruling 79-12: Amounts expended to enable an elected legislator to attend a political party's national convention as a delegate, which are paid from surplus funds from an earlier campaign maintained in a separate bank account qualifying as a political organization under Code section 527, are not includible in the legislator's gross income.

Revenue Ruling 79-11: A separate bank account used for depositing political contributions and disbursing bona fide political campaign expenses qualifies as a political organization under Internal Revenue Code section 527.

 


 

1978

 

Revenue Ruling 78-446: The exemptions from excise tax under Code sections 4041, 4221, and 4253, do not apply to sales of taxable liquids, articles, or communication services to a nonprofit children's day-care center for use in the center's Family Day Care Program that provides care for children in homes of a staff of trained child care personnel and operates according to the needs of the family being served; the exemptions do apply, however, to the center's Group Day Care and School Age Programs that normally maintain a regular faculty and curriculum and have a regularly enrolled student body of pupils or students in attendance at the place where its educational activities are regularly carried on.

Revenue Ruling 78-435: Sale of hearing aids to its patients by a section 501(c)(3) hospital whose primary activity is rehabilitating the handicapped, including those with hearing deficiencies, is not unrelated trade or business under Code section 513.

Revenue Ruling 78-434: A section 501(c)(6) exempt corporation, organized to finance crop operations, may own all the stock of a business corporation without loss of its exemption under that section.

Revenue Ruling 78-429: A nonprofit organization (1) formed to operate an airport located on land owned by a municipality that supervises its overall operations, (2) used by the general public and key local businesses essential to the economy of a four-county rural area having no other airport facilities, (3) using volunteers to provide administrative and maintenance services for the organization, and (4) using income derived from government grants, hangar rentals, and the sale of gasoline and oil for permanent improvements, maintenance, and daily operations, qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 78-428: A nonprofit organization formed and operated to provide legal services to indigent persons at a fee based upon the indigent clients' abilities to pay qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-426: An organization whose activities include inspecting, testing, and safety certification of cargo shipping containers and research, development, and reporting information in the field of containerization, is not operated exclusively for the purpose of testing for public safety or for scientific purposes, and does not qualify for exemption under section 501(c)(3).

Revenue Ruling 78-395: A disqualified person's transfer to a private foundation of real property that is subject to a lien placed on the property by the disqualified person within the 10-year period ending on the transfer date is an acting of self-dealing, even though the lien was created as part of a multiphase financing plan begun more than 10 years earlier.

Revenue Ruling 78-387: Where a private foundation having a carryover of excess qualify distributions as described in Code section 4942(i) transferred all its assets to another private foundation controlled by the same persons who controlled the first foundation, the transferee foundation may reduce its distributable amount under section 4942(d) by such carryover.

Revenue Ruling 78-386: A private foundation that supports only an organization that is terminating its private foundation status under an advance ruling pursuant to Code section 507(b)(1)(B)(i), and otherwise qualifies under section 1.509(a)-(4) of the regulations may be given an advance ruling that it can reasonably be expected to operate as a section 509(a)(3) organization and satisfy the requirements of section 507(b)(1)(B)(i) during its own 60-month termination period.

Revenue Ruling 78-385: A section 501(c)(3) organization is engaged in a taxable unrelated trade or business when, as an insubstantial part of its activities, it presents commercial broadcasting programs, religious or educational in nature, and sells advertising.

Revenue Ruling 78-384: A nonprofit organization that owns farmland and restricts its use to farming or other uses the organization deems ecologically suitable, but is not operated of the purpose of preserving ecologically significant land and does not otherwise establish that it serves a charitable purpose, does not qualify for exemption under Code section 501(c)(3). Rev. Rul. 76-204 is distinguished.

Revenue Ruling 78-315: An otherwise qualifying trust whose sole activity is operating a cultural center makes distributions qualifying it as an operating foundation under Code section 4942(j)(3)(A) when it turns over substantially all its annual adjusted net income to a separate corporation that, acting only in a fiduciary capacity on behalf of the trust, disburses such amount in a timely manner in the center's operation.

Revenue Ruling 78-310: An otherwise qualifying nonprofit organization formed to assist a school's law students, chosen based on merit and interest, to obtain practical experience with exempt public interest law firms and legal aid societies and that supplements the nominal salaries paid the students by participating firms and societies and obtains its funds from contributions of students and alumni, is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-309: A section 501(c)(3) organization, whose primary activity is providing courses of study in one of the martial arts consisting of regularly scheduled participatory exercises and theoretical discussions taught by a faculty of qualified instructors to a regularly scheduled student body, is an educational organization within the meaning of section 170(b)(1)(A)(ii), and, therefore, is not a private foundation.

Revenue Ruling 78-305: A nonprofit organization formed to educate the public about homosexuality in order to foster an understanding and tolerance of homosexuals and their problems qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-289: An organization whose exemption from tax under section 501(a) is revoked prospectively under the authority of section 7805(b) is subject to the unrelated business income tax for the period covered by section 7805(b) relief.

Revenue Ruling 78-288: An organization whose members are engaged in harness racing in a specific geographical area as drivers, trainers, and horse owners, most of whom are independent contractors or entrepreneurs, that negotiates with operators of area raceways for larger purses, better hours, and safer operating conditions does not qualify for exemption as a labor organization under Code section 501(c)(5).

Revenue Ruling 78-268: The portion of an electric generating facility owned by two investor-owned utilities as tenants in common with a municipally-owned utility and a tax-exempt section 501(c)(12) cooperative may qualify as section 38 property.

Revenue Ruling 78-248: Certain voter education activities conducted in a nonpartisan manner by a section 501(c)(3) exempt organization, will not be prohibited political activity disqualifying the organization from exemption.

Revenue Ruling 78-240: A section 501(c)(6) business league that receives reasonable compensation for sponsoring and endorsing an international commercial trade show, which is not a sales facility and at which the league performs educational and supporting services, is not engaged in unrelated trade or business under Code section 513.

Revenue Ruling 78-239: The dates of a period of war, for purposes of the definition of war veterans in section 1.501(c)(19)-1(b)(1) of the Income Tax Regulations, is the dates of periods of war set forth in 38 U.S.C. § 101 relating to veterans' benefits.

Revenue Ruling 78-238: IRS will not follow the decision in Peninsula Light Co., Inc. v . United States, 552 F.2d 878 (9th Cir. 1977), that an organization formed to distribute electric power to members, not operated on a patronage basis, whose charter instead provides that each member has an equal share in the organization's assets, with its net assets upon dissolution to be divided equally among its then-current members, and whose former members' rights and interests are forfeited upon termination of membership, qualifies for exemption as a mutual or cooperative organization under Code section 501(c)(12).

Revenue Ruling 78-232: An individual who claims to be a minister, organizes a church, deposits salary checks for salary from outside employment in the church's bank account, and uses the funds of the account for living expenses, is not entitled to a charitable contribution deduction for the amount of the salary checks.

Revenue Ruling 78-225: A nonprofit organization (1) operated to promote the common business interests of its members, a majority of whose businesses are located in a particular shopping center, (2) with a voluntary membership open to all businesses in a community, and (3) not concerned with landlord-tenant matters relating to the shopping center, qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 78-189: A fixed donation paid to the Church of Scientology for general education courses, religious education courses, and auditing and processing courses that does not exceed the fair market value of these courses is not a charitable contribution within the meaning of Code section 170.

Revenue Ruling 78-148: A private foundation may set aside under Code section 4942(g), by means of a bookkeeping entry, the amount by which its minimum investment return for its immediately preceding taxable year exceeds its adjusted net income for that year.

Revenue Ruling 78-145: Sale of plasma to commercial laboratories by an exempt blood bank, engaged in collecting and maintaining blood products for use by hospitals, is not unrelated trade or business where the blood bank sells either by-product plasma from which red blood cells have been removed for use by hospitals or plasma salvaged from whole blood nearing the end of its shelf life; sale of plasma derived from donors through plasma-pheresis or purchased from other blood banks is unrelated trade or business, however.

Revenue Ruling 78-144: A section 501(c)(3) organization's leasing of heavy machinery under long-term lease agreements requiring the lessee to provide insurance, pay applicable taxes, and make and pay for most repairs, with the functions of securing leases and processing payments performed for the organization without compensation, is not excepted from the term unrelated trade or business by reason of Code section 513(a)(1).

Revenue Ruling 78-143: A nonprofit organization, not associated with a cemetery company, formed by citizens of a community to maintain a cemetery whose lots were purchased from a landowner, qualifies for exemption under Code section 501(c)(13).

Revenue Ruling 78-132: A community cooperative organization formed to facilitate the exchange of personal services among members is operating primarily for the private benefit of its members and is not exempt from tax as a social welfare organization under Code section 501(c)(4).

Revenue Ruling 78-131: A nonprofit organization whose purpose is to develop and encourage interest in painting, sculpture, and other art forms by conducting, in a noncommercial manner, a community art show qualifies for exemption as an organization operated exclusively for the promotion of social welfare under Code section 501(c)(4).

Revenue Ruling 78-102: The correct conversion date of real property converted by a private operating foundation from nonexempt to exempt uses, for purposes of treating the conversion as a qualifying distribution under section 53.4942(a)-3(a)(5) of the regulations, is the date the foundation adopts and immediately proceeds to implement a plan for the property's exempt use, even though the conversion is not completed until the following year.

Revenue Ruling 78-100: A communal religious organization formed to promote the tenets and practices of a particular church, that does not conduct any business activities and is supported by wages earned by some of its members from outside employment, does not qualify for exemption under Code section 501(d).

Revenue Ruling 78-99: A nonprofit organization formed to provide counseling to widows to help them in legal, financial, and emotional problems caused by the death of their husbands, and that provides the widows with information on available benefits and services, is operated exclusively for educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-98: Recreational use of a ski facility operated by an exempt school by the school's students is substantially related to the school's exempt purposes and income derived from such use is not from an unrelated trade or business under Code section 513; income from use of the facility by members of the public is from unrelated trade or business, however.

Revenue Ruling 78-95: The two percent limitation prescribed by section 1.170A-9(e)(6)(i) of the Income Tax Regulations does not apply to the support received by an exempt charitable organization from individual churches described in Code section 170(b)(1)(i) that are publicly supported and entitled to section 170(b)(1)(A)(vi) status.

Revenue Ruling 78-90: Low-interest loans by a private foundation, established to help the blind secure employment, that are made to blind persons who desire to establish themselves in business but who are unable to obtain funds through commercial sources, are program-related investments under Code section 4944(c) and qualifying distributions under section 4942(g).

Revenue Ruling 78-88: Income an exempt organization derives from the temporary transfer of securities to a brokerage house to cover short sales by the brokerage house in exchange for collateral of equal value, which is held by the organization pursuant to a contract requiring the brokerage house to pay the organization an amount equivalent to the dividend or interest income that would have been earned by the securities plus either a premium based on a percentage of the value of the securities or income earned from investing the collateral, is not subject to tax under Code section 511.

Revenue Ruling 78-87: A fraternal beneficiary society that conducts an insurance operation for its members in all 50 states does not lose its exempt status by participating in a state-sponsored reinsurance pool that protects participating insurers from excessive losses on major medical health and accident insurance.

Revenue Ruling 78-86: The Service will not follow the decision in Monterey Public Parking Corporation v. United States, 481 F.2d 175 (9th Cir. 1973), that an organization formed by merchants to establish and operate a public off-street parking facility that provides free or reduced-rate parking for the merchants' customers through a validation stamp system qualifies for exemption as either a charitable corporation under Code section 501(c)(3) or a social welfare organization under section 501(c)(4).

Revenue Ruling 78-85: A nonprofit organization formed by residents of a city to help preserve, beautify, and maintain a public park located in the city and whose support is derived from membership dues and contributions from the general public, is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-84: An organization formed by citizens of a community to promote civic pride in the community, the state, and the country by providing a color guard and conducting flag-rising and other ceremonies at patriotic and community functions is promoting patriotism, a recognized charitable objective, and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-82: A section 501(c)(3) organization that offers lectures, workshops, and short courses on oriental philosophies and psychic phenomena, led by invited authorities and noted personalities in those fields and open to the general public as well as members, is not an educational organization within the meaning of section 170(b)(1)(A)(ii).

Revenue Ruling 78-77: A private foundation's purchase of property from a testamentary trust is not an act of self-dealing merely because a banking institution is the trustee of both the foundation and the testamentary trust, where the trust is not a disqualified person under Code section 4946(a) with respect to the foundation.

Revenue Ruling 78-70: A board of trade that, as its principal activity, provides grain analysis laboratory services to members and nonmembers at the same charge and that is supported almost entirely from the profits of the laboratory, which is of a kind customarily carried on for profit, is not exempt under Code section 501(c)(6).

Revenue Ruling 78-69: A nonprofit organization formed by residents of a suburban community to provide bus transportation between the community and employment centers during rush hours when the regular bus service is inadequate qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 78-68: An organization formed as a Model Cities demonstration project to provide bus transportation to isolated areas of a community not served by the existing bus system is providing bus service under the authority of the federal and local governments, and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 78-52: A section 501(c)(6) exempt association of credit unions that, as part of its activities, publishes and sells to members a consumer-oriented magazine designed as a promotional device for distribution to depositors, is engaged in an unrelated trade or business.

Revenue Ruling 78-51: Sale at a profit of standard legal forms to its members by a local bar association exempt under Code section 501(c)(6) is an unrelated trade or business under section 513.

Revenue Ruling 78-50: A nonprofit organization that processes consumer complaints about products and services provided by businesses, meets with the parties to encourage resolution, recommends a fair solution, and, if the proposed solution is not accepted, informs the parties about appropriate judicial or administrative bodies that may be used to resolve the disputes, qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 78-45: An amount contributed by a private foundation to another private foundation that, in the taxable year after the year in which it received the contribution, established an approved set-aside in the amount of the contribution and made a valid election to treat the entire amount of the set-aside as a distribution out of corpus, may be treated by the donor foundation as a qualifying distribution under Code section 4942.

Revenue Ruling 78-43: A travel tour program operated by a section 501(c)(3) university alumni association for members and their families, pursuant to which the association, working with travel agencies, schedules several tours annually to destinations around the world, mails out promotional material, accepts reservations, and is paid a fee by the travel agencies on a per person basis, is an unrelated trade ore business under Code section 513.

Revenue Ruling 78-42: A nonprofit apprenticeship and training committee formed by a union and an employers' association of a particular industry in connection with a collective bargaining agreement is exempt under Code section 501(c)(5) where it (1) conducts educational courses and programs for local members, employees, or associates of the industry to ensure that local standards on the quality of work conform with national industry codes, and (2) selects and supervises the training of apprentices.

Revenue Ruling 78-41: A trust created by an exempt hospital to accumulate and hold funds to satisfy malpractice claims against the hospital, and from which the hospital directs the bank-trustee to make payments to claimants, is operated exclusively for charitable purposes and is exempt from tax under Internal Revenue Code section 501(c)(3).

 


 

1977

 

Revenue Ruling 77-473: An elected member of a state legislature who receives a salary of less than $15,000 per year and an expense allowance of a fixed amount for the use of which no accounting need be made to the state, which together amount to more than $15,000 per year, is a disqualified person within the meaning of Code section 4946(a) by virtual of being a government official described in section 4946(c)(5).

Revenue Ruling 77-469: An organization that filed an application for recognition of exemption under Code section 501(c)(3) in May 1976, after its incorporation in November 1975 to succeed an unincorporated association that had operated for three years without filing an application, will be recognized as exempt from the date of incorporation; an advance ruling concerning the organization's private foundation status may be requested based on support received since incorporation.

Revenue Ruling 77-434: Long-term, low-interest educational loans made by a private foundation under a program that specifically limits the use of the funds to furtherance of the recipient's education at an educational institution described in Code section 170(b)(1)(A)(ii) are individual grants within the meaning of section 4945(g)(3).

Revenue Ruling 77-430: An otherwise qualifying nonprofit organization that conducts weekend religious retreats, open to individuals of diverse Christian denominations, at a rural lakeshore site at which the participants may enjoy the recreational facilities in their limited amount of free time and that charges no fees qualifies for exemption under Code section 501(c)(3) and operated exclusively for religious purposes.

Revenue Ruling 77-429: An exempt section 501(c)(2) title-holding corporation may retain part of its income each year to apply to indebtedness on property to which it holds title; the transaction will be treated as if the income had been turned over to the exempt parent which had used the income to make a capital contribution to the title holding corporation which, in turn, applied the contribution to the indebtedness; Rev. Rul. 67-104 superseded in part and obsoleted in part.

Revenue Ruling 77-407: The requirement of section 1.170A-9(e)(5)(i) of the regulations that an organization must have been in existence for at least one taxable year consisting of at least eight months to obtain a ruling or determination letter that it is not a private foundation by virtue of being described in Code sections 509(a)(1) and 170(b)(1)(A)(vi) does not apply to section 170(b)(1)(A)(iv) organizations.

Revenue Ruling 77-381: A church-affiliated college exempt from tax under Code section 501(c)(3) that trains ministers and lay workers to serve religious functions in the church is an integrated auxiliary of a church within the meaning of section 1.6033-2(g)(5)(i) of the regulations and is not required to file an annual return on Form 990.

Revenue Ruling 77-380: Grants made by a private foundation primarily in recognition of past achievement, with the funds being unrestricted, or earmarked for subsequent travel or study and meeting the requirements of Code section 4945(g), are not taxable expenditures within the meaning of section 4945.

Revenue Ruling 77-379: A private foundation's transfer of stock in repayment of an interest-free loan, made by a disqualified person and used exclusively for exempt purposes, is tantamount to a sale or exchange of property between the private foundation and the disqualified person and is an act of self dealing under Code section 4941(d)(1)(A).

Revenue Ruling 77-367: A nonprofit organization formed to create and operate a replica of an early American village is engaging in educational activities similar to those of a museum and qualifies for exemption under Code section 501(c)(3) even though the corporation that donated the land and a substantial percentage of the organization's support benefits by having the village named after it and by having its name associated with the village through both the corporation's and the organization's advertising.

Revenue Ruling 77-366: A nonprofit organization that arranges and conducts winter-time ocean cruises during which activities to further religious and educational purposes are provided (in addition to extensive social and recreational activities) is not operated exclusively for exempt purposes and does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 77-365: An otherwise qualifying nonprofit organization that conducts clinics, workshops, lessons, and seminars at municipal parks and recreational areas, to instruct and educate individuals in a particular sport, is operated exclusively for educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 77-352: Bonds issued by a political subdivision to construct an office building to be owned by a tax-exempt hospital that will lease the office space primarily for the individual and private practice of doctors, who are not employees but are affiliated with the hospital, will be industrial development bonds, interest on which is not tax-exempt, even though the leasing is not an unrelated trade or business.

Revenue Ruling 77-334: Examples of resolutions adopted by community trusts with respect to the administration of such trusts or funds that satisfy the requirements of section 1.170A-9(e)(11)(v)(E) and (F) of the regulations.

Revenue Ruling 77-333: Examples of provisions in the governing instruments of community trusts that meet the requirements of section 1.170A-9(e)(11)(v)(B) of the regulations.

Revenue Ruling 77-331: Guarantee of loans made to disqualified persons under a student loan guarantee program established by a private foundation for the children of its employees is an act of self-dealing under Code section 4941(d)(1)(E).

Revenue Ruling 77-290: Circumstances under which amounts received as remuneration by a member of a religious order under a vow of poverty from employment outside the order are includible in the member's gross income for federal income tax purposes and subject to payroll taxes.

Revenue Ruling 77-288: The purchase by a private foundation from a banking institution, a disqualified person with respect to the foundation, of certificates of deposit with a maturity date one year from the date of issue and providing for a reduced rate of interest if they are not held to the maturity date is an act of self-dealing under Code section 4941(d)(1)(B).

Revenue Ruling 77-273: A nonprofit organization that provides security services for residents and property owners of a community, who agree to donate money voluntarily at a specified hourly rate to defray the cost of the services, is carrying on a business with the general public in a manner similar to organizations operated for profit and does not qualify for exemption under Code section 501(c)(4).

Revenue Ruling 77-272: An organization formed and operated by a labor union at the request of the Bureau of Indian Affairs to provide apprentice training in a skilled trade to American Indians is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 77-261: Income from a fund, established under a written declaration of trust by a state, for the temporary investment of cash balances of the state and its political subdivisions, which purchases units of participation and have an unrestricted right of withdrawal, is excludible from gross income; however, the fund is classified as a corporation and must file a federal income tax return.

Revenue Ruling 77-259: The purchase by a private foundation of a mortgage from a bank, a disqualified person that in the normal course of its business acquires and sells mortgages, is not within the exception for general banking services and is an act of self-dealing under Code section 4941(d)(1)(A).

Revenue Ruling 77-258: A domestic fraternal society operating under the lodge system, which does not provide life, sick, accident, or other benefits, whose members are interested in the use of and philosophy behind a method of attempting to divine the future, and whose net income is used to provide instruction on the use of the method, maintain a reference library, and supply information on the method to the public, qualifies for exemption under Code section 501(c)(10).

Revenue Ruling 77-255: Contributions by a section 501(c)(6) business league to a section 501(c)(3) organization seeking to be classified as other than a private foundation under section 509(a)(1) because it is publicly supported under section 170(b)(1)(A)(vi) are subject to the two percent limitation imposed by section 1.170A-9(e)(6) of the Income Tax Regulations.

Revenue Ruling 77-252: A private foundation that made an interest-free loan from corpus to a public charity in a year in which its distribution requirements had been met and that continued to meet the distribution requirements during the five-year period without use of the excess of qualifying distributions created by the loan is not required to include in its gross income repayments on the loan and may return the payments to corpus.

Revenue Ruling 77-251: A per diem allowance for travel inside the United States paid to a government official by a private foundation in connection with its educational and charitable purposes is excepted from the tax on self-dealing under Code section 4941(d)(2)(G)(vii) only if the allowance does not exceed 125 percent of the maximum authorized rate of $35 provided by 5 U.S.C. § 5702(a), notwithstanding the provision in section 5702(c) allowing higher rates in designated geographical areas.

Revenue Ruling 77-246: A nonprofit organization that provides, upon request, low cost bus transportation to senior citizens and handicapped persons in a community where public transportation is unavailable or inadequate qualifies for exemption under Code section 501(c)(3) because it is operated exclusively for charitable purposes.

Revenue Ruling 77-213: A private foundation that failed to list on its original annual information return a grant to an organization not described in either section 509(a)(1), (2), or (3) of the Code, but corrected the omission on an amended return filed after the due date, has failed to exercise the expenditure responsibility requirements of section 4945(h)(3) with respect to the grant, and the grant is a taxable expenditure.

Revenue Ruling 77-212: Grants by a private foundation to vocational high schools to be used to purchase the basic tools of a trade for students selected by representatives of the foundation are grants to individuals for study and will be taxable expenditures unless the requirements of Code section 4945(g) are met.

Revenue Ruling 77-211: A nonprofit organization operating an improvisational repertory theater and workshops in the study and production of improvisational theater does not qualify as a nonprofit educational organization exempt from tax under Code section 501(c)(3); however, the organization's workshops, which meet the requirements relating to faculty, curriculum, and enrolled study body, qualify as a school operated as an activity of an exempt organization and are exempt from certain excise taxes.

Revenue Ruling 77-208: A corporation that states it is a publicly supported charity when it files its application after the deadline provided by regulation cannot be treated as an organization described in section 501(c)(3) of the Code before the date it files its application; financial support received prior to that date may not be used for purposes of determining whether the organization is publicly supported.

Revenue Ruling 77-207: A corporation that states it is a private foundation when it files an application for recognition of exemption after the deadline provided by regulation is treated as an organization described in Code section 501(c)(3) and as a private foundation only from the date it files its application.

Revenue Ruling 77-206: Cash rebates made by an exempt business association to member and nonmember exhibitors who participate in the association's annual industry trade show, that represent a portion of an advance floor deposit paid by each exhibitor to insure the show against financial loss, are made to all exhibitors on the same basis, and may not exceed the amount of the deposit, do not adversely affect the association's exempt status under Code section 501(c)(6).

Revenue Ruling 77-161: A private foundation's loan to a disqualified person that constitutes an act of self-dealing, but otherwise is a permissible expenditure, is not a taxable expenditure within the meaning of Code section 4945(d)(5).

Revenue Ruling 77-160: A private foundation's payment of a disqualified person's church membership dues in order to maintain that person's church membership is an act of self-dealing under Code section 4941(d)(1)(E).

Revenue Ruling 77-154: A nurses' association whose membership includes a small percentage of self-employed private duty nurses and whose primary activity is acting as a collective bargaining agent for its members qualifies for exemption as a labor organization under Code section 501(c)(5).

Revenue Ruling 77-153: A nonprofit organization that owns and operates a livestock facility and leases it to local members of a nonexempt national association of farmers for use in implementing the association's collective bargaining program with processors does not qualify for exemption as an agricultural organization under Code section 501(c)(5).

Revenue Ruling 77-116: Support received by an organization before changes made in its operations to enable it to qualify under Code section 501(c)(3) is not taken into account in determining its foundation status under section 509.

Revenue Ruling 77-115: A newly created organization, exempt from tax under Code section 501(c)(3), that wishes to obtain an extended advance ruling for purposes of determining whether it will qualify as a publicly supported organization must submit a request for the extended advance ruling at the same time as its request for an initial advance ruling. Note that the extended advance ruling period procedure is superseded by one five-year advance ruling period in repsonse to Congressional directive contained in the Confernece Committee Report to the Deficit Reduction Act of 1984.  See H.R. Rep. No. 98-861, 2d Sess. 1 (1984), 1984-3 C.B. Vol. 2 1090.  The regulations have not been updated to reflect this change, however.

Revenue Ruling 77-114: The date of notice for purposes of Code section 508(a) (the requirement to file Form 1023) is the date of the U.S. postmark stamped on the cover in which an exemption application is mailed or, if no postmark appears on the cover, the date the application is stamped as received by the Service.

Revenue Ruling 77-112: An organization composed of persons studying for a degree in a particular profession may be an association of persons having a common business interest within the meaning of section 1.501(c)(6)-1 of the Income Tax Regulations.

Revenue Ruling 77-111: An organization formed to increase business patronage in a deteriorated area by providing information on the area's shopping opportunities, local transportation, and accommodations, is not operated exclusively for charitable purposes and does not qualify for exemption under Code section 501(c)(3). Similarly, an organization whose purpose is to revive retail sales in an area of economic decline by constructing a shopping center does not qualify for exemption.

Revenue Ruling 77-74: Amounts accumulated by a private foundation created in 1968 to award scholarships to qualified individuals from a specific high school, as required by the trust instrument, do not reduce the amount required to be distributed under Code section 4942, even though a probate court of competent jurisdiction denied the trustee's request to be excused from compliance with the provision of the trust requiring the accumulation.

Revenue Ruling 77-72: Indebtedness owed to a labor union by its wholly-owned tax-exempt subsidiary title-holding company resulting from a loan to pay debts incurred to acquire two income-producing office buildings is not acquisition indebtedness within the meaning of Code section 501(c).

Revenue Ruling 77-71: The transfer, subject to an existing mortgage, of an appreciated apartment complex by a tax-exempt section 501(c)(3) hospital to its wholly owned taxable subsidiary in exchange for additional stock in the subsidiary does not result in a gain with respect to which the hospital will be taxed under Code section 511.

Revenue Ruling 77-70: A nonprofit cemetery company that acquires land from a for-profit cemetery company, under an agreement providing payment to the former owners based on a percentage of the sales price of each cemetery lot sold, is not exempt form tax as a cemetery described in section 501(c)(13); Rev. Rul. 61-137 amplified.

Revenue Ruling 77-69: A Health Systems Agency organized and operated pursuant to the National Health Planning and Resources Development Act of 1974 to establish and maintain a system of health planning and resources development aimed at providing adequate health care for a specified geographic area is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 77-68: A nonprofit organization formed to provide individual psychological and educational evaluations, as well as tutoring and therapy for children and adolescents with learning disabilities, operates exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 77-47: Buildings acquired through assumption of outstanding mortgages by an exempt organization that restores, preserves, and exhibits buildings of historical and/or architectural significant, constitute debt-financed property within the meaning of Code section 514(b)(1) when they are leased at fair rental; value for uses that neither bear nay relationship to the buildings' historical or architectural significance nor accommodate viewing by the general public.

Revenue Ruling 77-46: A nonprofit organization established under a collective bargaining agreement between a union and an employers' association to enable members of the union to save money by having a set amount withheld from their pay and deposited in a bank account, the funds to be paid to them annually with any interest remaining after payment of administration expenses, fails to qualify for tax exemption under Code section 501(c)(5).

Revenue Ruling 77-44: Grants made on an objective and nondiscriminatory basis by a private foundation to worthy college students who acknowledge that they plan to teach in a particular state after graduation satisfy the requirements of section 4945(g) of the Code and are not taxable expenditures under section 4945(d)(3); however, because they are grants to achieve specific objectives as described in section 4945(g)(3) rather than constituting scholarships as described in section 4945(g)(1), the grants are not excludable from recipients' gross income under section 117(a) as scholarships.

Revenue Ruling 77-43: A trust established pursuant to a collective bargaining agreement between an association of employers and a labor union to compensate union members for anticipated lost wages because of the adoption of a new loading process in the shipping industry, with eligibility for benefits not limited to those union members suffering a loss of hours worked or wages, does not qualify for exemption under Code section 501(c)(17).

Revenue Ruling 77-42: A nonprofit organization that sets up closed-circuit radio transmitting equipment in multiple residence structures such as nursing homes, rest homes, and convalescent homes, providing senior citizens in the buildings an opportunity to listen to free, non-commercial, and educational broadcasts concerning their special needs, is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 77-7: The term "specific project" as defined in section 53.4942(a)-3(b)(2) of the Foundation Excise Tax Regulations includes a project to be undertaken by a public charity unrelated to the private foundation.

Revenue Ruling 77-6: The purchase of part of a bond issue on behalf of an section 501(c)(3) exempt hospital by a disqualified person with respect to a private foundation that guaranteed the bonds (other than those sold to the disqualified person) is not an actual of self-dealing.

Revenue Ruling 77-5: A trust, established pursuant to a collective bargaining agreement, that is funded and administered by the employers in an industry to compensate a multi-employer steward who is under the union's direct control with responsibility to settle disputes, investigate complaints, and otherwise encourage compliance with the agreement throughout the whole industry, is a trust qualifying for exemption as a labor organization under section 501(c)(5).

Revenue Ruling 77-4: A nonprofit organization, whose only activities are preparing and publishing a newspaper of local, national, and international news articles with an ethnic emphasis, soliciting advertising, and selling subscriptions to that newspaper in a manner indistinguishable from ordinary commercial publishing practices, is not operated exclusively or charitable and educational purposes and does not qualify for exemption under section 501(c)(3).

Revenue Ruling 77-3: A nonprofit organization that provides rental housing and related services at cost to a city for its use as free temporary housing for families whose homes have been destroyed by fire is not an exempt charitable organization under Internal Revenue Code section 501(c)(3).

 


 

1976

 

Revenue Ruling 76-461: An award by a private foundation to a high school senior whose exhibit receives top honors in a local science fair and is conditioned on the student's agreeing to use the award for educational activities may be a taxable expenditure under Code sections 4945(d)(3) and 4945(g); Revenue Ruling 75-393 distinguished.

Revenue Ruling 76-460: An unconditional and unrestricted grant by a private foundation to the winner of a competition among students attending schools specializing in teaching a special craft is not a taxable expenditure within the meaning of Code section 4945(d); Revenue Ruling 75-393 modified.

Revenue Ruling 76-459: The use of a private foundation museum's private road for access to the adjacent headquarters and manufacturing plant of a corporation (a disqualified person) during the same hours the general public uses the road as a thoroughfare conducting two public streets, is not an act of self-dealing.

Revenue Ruling 76-457: A domestic fraternal beneficiary society of farmers, operated under the lodge system, that does not itself provide for the payment of life, sick, accident, or other benefits to its members, but arranges with insurance companies to provide optional insurance to members and devotes its net earnings exclusively to religious charitable, scientific, literary, educational, and fraternal purposes does not qualify for exemption under Code section 501(c)(8) but does qualify under section 501(c)(10).

Revenue Ruling 76-456: An organization formed to elevate the standards of ethics and morality in the conduct of political campaigns, that disseminates information about general campaign practices, furnishes teaching aids to political science and civics teachers, and publicizes its proposed code of fair campaign practices without soliciting the signing or endorsement of the code by candidates qualifies as an educational organization under Code section 501(c)(3).  Revenue Ruling 66-258 modified and superseded for taxable years beginning after 1976.

Revenue Ruling 76-455: A nonprofit organization formed to help establish nonprofit regional health data systems, to conduct studies and propose improvements in quality, utilization, and effectiveness of health care and health care agencies, and to educate those involved in furnishing, administering, and financing health care is operated exclusively for scientific and educational purposes and qualifies for exemption under Code section 501(c)(3).  Distinguishing Revenue Ruling 74-553.

Revenue Ruling 76-452: An exempt organization primarily providing health services to sick persons in their homes under the direction of their private physicians and providing only incidental patient treatment at the organization's office, which is not equipped to serve as an outpatient facility on a continuing basis, does not qualify as a hospital defined in Code section 170(b)(1)(A)(iii).

Revenue Ruling 76-448: An act of self-dealing will not result from the exchange of securities between a private foundation and a corporation that was previously a disqualified person because it owned more than 35 percent of its total combined voting power by the former foundation manager, who resigned 5 years before the exchange, and who did not participate in planning the exchange offer while he was disqualified.

Revenue Ruling 76-443: A nonprofit organization that makes facilities and equipment available to the public to produce noncommercial educational or cultural television programs for communication to the public via public and educational channels of a commercial cable television company, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-442: A nonprofit organization whose primary activity is offering free legal services for personal tax and estate planning to individuals who wish to make current and deferred gifts to charity as part of their tax and estate planning does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 76-441: An otherwise qualifying nonprofit organization that purchases or leases at fair market value the assets of a former for-profit school and employs the former owners, who are not related to the current directors, at salaries commensurate with their responsibilities, is operated exclusively for educational and charitable purposes. An organization that takes over a school's assets and liabilities, which exceed the value of the assets and include notes owed to the former owners/current directors of the school, is serving the directors' private interests and is not operated exclusively for educational and charitable purposes.

Revenue Ruling 76-440: A large inter vivos gift of undeveloped land from a disinterested donor to a Code section 501(c)(3) organization, conditioned on the land's being used in perpetuity to further the exempt organization's purposes of preserving natural resources, is an unusual grant and will not adversely affect the organization's status as a publicly supported organization under section 170(b)(1)(A)(vi).

Revenue Ruling 76-424: Appreciated stock distributed to a private foundation in 1971, to satisfy a specific bequest and a percentage of the residuary estate of an individual who died in 1967, will be considered held by the foundation on December 31, 1969, and the basis of the stock for purposes of computing capital gain includible in net investment income will be the fair market value of the stock as of December 31, 1969, under section 4940(c)(4)(B) of the Code.

Revenue Ruling 76-420: An organization, controlled by private individuals, that provides weekly income to members in the event of a lawful strike by the members' labor union, in return for an annual payment by members, does not qualify for exemption as a labor organization under Code section 501(c)(5).

Revenue Ruling 76-419: A nonprofit organization that purchases blighted land in an economically depressed community, converts the land into an industrial park, and encourages industrial enterprises to locate new facilities in order to provide employment opportunities for low income residents of the area, is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-418: A nonprofit organization, formed to initiate and develop programs to reduce vehicle deaths and injuries by providing free expert opinions to local government officials about hazardous traffic conditions in the community and conducting programs to inform the public about traffic safety, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-417: A organization exempt under section 501(c)(3) of the Code, that conducts an internship program placing college and university students with cooperating government agencies for a semester, is not an educational organization described in section 170(b)(1)(A)(ii) and is a private foundation unless otherwise described in section 509(a).

Revenue Ruling 76-416: A hospital described in Code section 170(b)(1)(A)(iii) is not prevented by Treas. Reg. § 1.170A-9(e)(1) from qualifying as a publicly supported organization under section 170(b)(1)(A)(vi) if it desires that additional classification.

Revenue Ruling 76-410: A nonprofit organization of insurance companies operating within a state, which was created under the state's no-fault insurance statute to provide personal injury protection benefits for residents of the state who sustain injury in situations where the injuring party is unknown or has very limited or no liability coverage, qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 76-409: A nonprofit organization of individuals in the business of furnishing finance adjusting services, which assigns exclusive franchise areas to its members and publishes and distributes to their potential customers a directory of members' names and addresses, is performing particular services for its members and does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 76-408: A nonprofit organization that provides interest-free home repair loans in a badly deteriorated residential area to low-income homeowners who cannot obtain loans elsewhere is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-402: An exempt school annually contracts with an individual who conducts a 10-week summer tennis camp with the school furnishing the tennis courts, housing, and dining facilities and the individual hiring the instructions, recruiting campers, and providing supervision. Amounts received are from dual use of facilities and personnel; therefore, an allocable portion of expenses attributable to such facilities and personnel may be deducted in computing unrelated business taxable income under Code section 512.

Revenue Ruling 76-401: An exempt charitable trust whose sole purpose is to grant scholarships to students graduating from public or private high schools in a city and whose trustees are officers of, or are elected by the membership of, a local civic league exempt under Code section 501(c)(4), is a supporting organization within the meaning of section 509(a)(3) and thus not a private foundation.

Revenue Ruling 76-400: A nonprofit membership organization of business and professional women that promotes acceptance of women in business and the professions qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 76-399: A nonprofit organization of growers and producers of an agricultural commodity formed principally to negotiate with processors for the price to be paid members for their crops qualifies for exemption under Code section 501(c)(5).

Revenue Ruling 76-384: A section 501(c)(3) organization that operates a tutoring service for students on a one-to-one basis in their homes, maintains a small center to test students to determine their need for individual tutoring, and employs tutors on a part-time basis, is not an educational organization of the type described in Code section 170(b)(1)(A)(ii).

Revenue Ruling 76-366: An association of investment clubs formed to enable members and prospective investors to make sound investments by the mutual exchange of investment information, that carries on not only educational activities but other activities to support and promote the economic interest of its members, does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 76-354: Income an exempt organization derives from mineral production payments purchased with borrowed funds is unrelated business taxable income to the extent specified in Code section 514.

Revenue Ruling 76-341: The small remuneration a section 501(c)(3) religious organization paid its members for services they performed pursuant to contracts between the organization and third parties is wages for purposes of the FICA and income tax withholding; contract amounts paid to the organization are not includible in the members' gross income but are unrelated business taxable income under Code section 511.

Revenue Ruling 76-340: Scholarship grants made to individuals by a private foundation based on academic standing, financial need, personal history, cost of programs of study to be pursued, and likelihood that recipients will be able to finance the balance of the cost of their education, are not taxable expenditures within the meaning of Code section 4945(d)(3).

Revenue Ruling 76-337: Interest on obligations of a state received by a social club exempt under Code section 501(c)(7) is not included in gross income for the purpose of computing unrelated business taxable income under section 512(a)(3).

Revenue Ruling 76-336: A nonprofit organization, formed to provide housing for students of a college unable to provide adequate student housing and located in a community in which suitable housing is not otherwise available, is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-335: An organization incorporated as a subsidiary of an exempt title-holding corporation for the exclusive purpose of holding title to investment property, collecting the income therefrom, and turning over such income, less expenses, to the parent, qualifies for exemption under Code section 501(c)(2).

Revenue Ruling 76-330: A Belgian private foundation, whose only business activities in the United States are investments from which it derives interest income, is not exempt from the excise tax on gross investment income imposed by Code section 4948(a).

Revenue Ruling 76-297: Amounts received from licensees by an exempt organization, the legal and beneficial owner of patents assigned to it by inventors for specified percentages of future royalties, is excludable in computing unrelated business taxable income. Distinguishing Revenue Ruling 73-193.

Revenue Ruling 76-296: Commercially sponsored research otherwise qualifying as scientific research under Code section 501(c)(3), the results of which are timely published so as to be available to the interested public, is scientific research carried on in the public interest. Research, the publication of which is withheld or delayed significantly beyond the time reasonably necessary to establish ownership rights, however, is not in the public interest and is the conduct of unrelated trade or business within the meaning of Code section 513.

Revenue Ruling 76-262: A religious organization that applies for recognition of its status after expiration of the time set forth under Code section 508(a) will not be treated as a section 501(c)(3) organization for the period before which its application was filed; services performed by its employees during that period are not excepted from employment for FICA and FUTA purposes.

Revenue Ruling 76-244: A nonprofit organization that provides home delivery of meals to elderly and handicapped people by volunteers, for a fee not covering the cost of operations but approximating the cost of meals, or for a reduced fee or no fee depending on a recipient's ability to pay, is operated for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-237: An exempt organization whose primary function is conducting guided tours, during which participants are instructed in the skills and crafts of the area they are touring, does not qualify as a nonprofit educational organization for purposes of the exemption from the communications, manufacturers, and retailers taxes.

Revenue Ruling 76-208: An section 501(c)(3) trust whose trust instrument designates a bank as sole trustee and provides that 75 percent of the trust income be distributed annually to a specified church with the remaining 25 percent to accumulate until the original corpus doubles, at which time the entire annual income is to be distributed to the church, does not satisfy the substantially all requirement of the integral part test set forth in Treas. Reg. sec. 1.509(a)-4(i)(3)(iii)(a) of the regulations and is not a section 509(a)(3) supporting organization.

Revenue Ruling 76-207: A nonprofit organization, formed by a city's civic leaders, public officials, businessmen, and representatives of the community at large, to encourage conventions of national organizations in the city by making arrangements for facilities, services, and administrative support necessary to run a convention, qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 76-206: A nonprofit organization formed to generate community interest in retaining classical music programs by a local for-profit radio station by seeking program sponsors, encouraging continuation of contracts by existing sponsors, urging the public to patronize sponsors, soliciting subscriptions to the station's program guide, and distributing materials promoting the classical music programs, all of which tend to increase the station's revenues, does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 76-205: A nonprofit organization formed to help immigrants overcome social, cultural, and economic problems by providing personal counseling, referrals, social and recreational activities, and English instruction, and by distributing a newsletter with information on attaining citizenship, securing housing, and obtaining medical care, is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-204: A nonprofit organization formed to preserve the natural environment by acquiring, by gift or purchase, ecologically significant undeveloped land, and either maintaining the land itself with limited public access or transferring the land to a government conservation agency by outright gift or being reimbursed by the agency for its cost, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 76-167: A nonprofit organization established to operate a museum which, as part of its program, offers accredited programs with a regular faculty and curriculum to students of a local university and a lecture series open to students and the general public, is not a nonprofit educational organization exempt from retailers, manufacturers, and communications excise taxes; however, the seminar and degree programs are educational activities that qualify as a school within the meaning of the term nonprofit educational organization and the exemptions from tax apply to sales of articles or services to the organization for exclusive use in these programs.

Revenue Ruling 76-159: The payment or reimbursement by a private foundation of expenses incurred by a trustee, a government official of the Commonwealth of Puerto Rico, for roundtrip travel from Puerto Rico to the U.S. to attend the foundation's trustee meetings does not constitute an exception to self-dealing under Code section 4941(d)(2)(G)(vii).

Revenue Ruling 76-158: A private foundation, owning 35 percent of the voting stock of a corporation and having a foundation manager personally owning the remaining 65 percent but not holding a position of authority ion the corporation by virtue of being a foundation manager, does not control the corporation for purposes of the self-dealing provisions of Code section 4941.

Revenue Ruling 76-152: A nonprofit organization formed by art patrons to promote community understanding of modern art trends by selecting for exhibit, exhibiting, and selling art works of local artists, retaining a commission on sales less than customary commercial charges and not sufficient to cover the cost of operating the gallery, does not qualify for exemption under Code section 501(c)(3). Revenue Ruling 71-395 clarified.

Revenue Ruling 76-147: An organization formed to improve conditions in an area of a city where the income level is higher and housing better than in other areas of the city and whose activities include providing general information on methods of counteracting housing deterioration and ways of improving homes may qualify for exemption under Code section 501(c)(3). Revenue Ruling 67-6 modified.

Revenue Ruling 76-95: A section 501(c)(3) exempt organization that acquires an undivided interest in rental property subject to a mortgage and prepays its proportionate share of the mortgage indebtedness, receiving releases of liability from the mortgagee and co-owners, has no acquisition of indebtedness within the meaning of Code section 514(c)(1), even though the entire property remains encumbered by the mortgage.

Revenue Ruling 76-94: An exempt organization's operation of a retail grocery store as part of its therapeutic program for emotionally disturbed adolescents, almost fully staffed by the adolescents, and on a scale no larger than is reasonably necessary for the performance of the organization's exempt functions, is not unrelated trade or business within the meaning of Code section 513. Distinguishing Revenue Ruling 73-127.

Revenue Ruling 76-93: Income derived by a section 501(c)(3) organization from the sale of space in its journal for advertising, except space for 60-to-the page listing that merely identifies the purchaser without a further advertising message, constitutes unrelated trade or business income. Clarifying Revenue Ruling 74-38.

Revenue Ruling 76-92: A nonexempt charitable trust described in Code section 4947(a)(1) that is a private foundation must terminate its private foundation status pursuant to section 507 before it can be excluded from such status under section 509(a)(3).

Revenue Ruling 76-91: The purchase, in a transaction not at arm's length, of all of the assets of a profit-making hospital by a nonprofit hospital at a price that includes the value of intangible assets, determined by the capitalization of excess earnings formula, does not result in the inurement of the hospital's net earnings to the benefit of any private shareholder or individual or serve a private interest precluding exemption under Code section 501(c)(3).

Revenue Ruling 76-85: In determining its minimum investment return under Code section 4940, a private foundation need not take into account assets used in a trade or business for which substantially all the work is performed without compensation.

Revenue Ruling 76-81: A nonprofit organization formed to educate the public on the subject of abortions, promote the rights of the unborn, and support legislative and Constitutional changes to restrict women's access to abortions qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 76-38: A nonprofit organization formed to maintain the good will and reputation of credit unions in a state by making interest free loans to help credit unions in financial difficulty, with no restrictions place upon the use of the funds, does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 76-37: A nonprofit organization that purchases building lots, furnishes funds to a public vocational training center to use in its on-the-job home construction training program, sells the completed homes to the general public at fair market value, and uses the income from home sales to finance new projects and obtain vocational training equipment for the public school system, qualifies for exemption under Code section 501(c)(3); income from the sale of the homes is not unrelated business income.

Revenue Ruling 76-33: Rental of dormitory rooms and similar residential accommodations, primarily to people under age 25, by an exempt organization whose purpose is to provide for the welfare of young people, is substantially related to the organization's exempt purpose and is not an unrelated trade or business within the meaning of Code section 513.

Revenue Ruling 76-32: Reports described in the example in Treas. Reg. § 1.509(a)(4)(i)(3)(iii)(d), submitted by the trustee to each beneficiary of a charitable trust, will not alone satisfy the attentiveness requirement of the integral part test for classification as a section 509(a)(3) supporting organization.

Revenue Ruling 76-31: A city school teacher's association, formed to improve its members' professional abilities and secure better salaries and working conditions for them, that sponsors seminars and courses for its members, participates in teacher conventions, bargains collectively and processes grievances, and keeps its members informed of its activities through regular meetings and a newsletter, may qualify for exemption as a labor organization under Code section 501(c)(5).

Revenue Ruling 76-22: An organization that provides free legal services and funds needed to pay commercial bondsmen's fees for indigent persons accused of crimes is operated exclusively for charitable purposes.

Revenue Ruling 76-21: An organization that posts its own money or property with the court as bail for indigent defendants unable to provide funds with which to post bail, as part of its integrated program of providing services to persons accused of crimes, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 76-18: Sale of a private foundation's art objects to a disqualified person at a public auction conducted by a gallery to which the items were consigned for sale is an act of self-dealing.

Revenue Ruling 76-10: A government official's use of a private foundation library's meeting room, which is functionally related to the foundation's exempt purpose and is made available at no charge to members of the community, is not self dealing under Code section 4941.

Revenue Ruling 76-5: A public interest law firm does not qualify for exemption under Code section 501(c)(3) if it enters into a fee-sharing arrangement with a private attorney who will keep the portion of any court-awarded fee that exceeds the amount the firm has paid to the attorney for services rendered on the particular case.

Revenue Ruling 76-4: Criteria for exemption under Internal Revenue Code section 501(c)(3) of an organization that produces and distributes programs for public viewing via public educational channels of commercial cable television companies.

 


 

1975

 

Revenue Ruling 75-511: A private foundation, whose primary activity is making renewable scholarships and fixed sum research grants that normally run for three years, for which payments have been made annually from current income, may not treat set-aside amounts representing the maximum for each grantee from which the annual payments will be made as qualifying distributions under Code section 4942(g)(2).

Revenue Ruling 75-495: Legal fees not excessive in amount, paid by an exempt charitable trust in a suit to determine the proper beneficiary of a portion of its net income, are qualifying distributions under Code section 4942(g)(1).

Revenue Ruling 75-494: A club providing social and recreational facilities, whose membership is limited to homeowners of a housing development, will be precluded from qualifying for exemption under Code section 501(c)(7) by owning and maintaining residential streets, enforcing restrictive covenants, or providing residential fire and police protection and trash collection service.

Revenue Ruling 75-492: An exempt organization, not publicly supported, whose primary activity is providing specialized instruction by correspondence and that also offers a five- to ten-day seminar program of personal instruction for students who have completed the correspondence course is not an organization described in Code section 170(b)(1)(A)(ii) and is a private foundation as defined in section 509(a).

Revenue Ruling 75-473: A nonprofit organization, controlled and funded jointly by a labor union and an employer association, that operates a dispatch hall to allocate work assignments among union members and engages in other activities appropriate to a labor union, qualifies for exemption as a labor organization under Code section 501(c)(5).

Revenue Ruling 75-472: A halfway house, organized to provide room, board, therapy, and counseling for persons discharged from alcoholic treatment centers, which also operates a furniture shop to provide full-time employment for its residents with any profits applied to operating costs of the halfway house, qualifies for exemption under Code section 501(c)(3) and is not conducting an unrelated trade or business within the meaning of section 513.

Revenue Ruling 75-471: A nonprofit organization formed to promote the art of filmmaking by conducting annual festivals to provide unknown independent filmmakers with opportunities to display their films and by sponsoring symposiums on filmmaking qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-470: A nonprofit organization formed to promote an appreciation of history through the acquisition, restoration, and preservation of homes, churches, and public buildings having special historical or architectural significance and to open the structures for viewing by the general public qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-443: Repayments of principal received by a private foundation in taxable years beginning after 1969 on loans made in prior years to individuals for charitable purposes are not includible in its gross income to determine its adjusted net income for purposes of Code section 4942(f); payments of interest on such loans are includible, however.

Revenue Ruling 75-442: For purposes of section 4942 of the Code, a private foundation receiving annual payments, as beneficiary of a decedent's deferred incentive compensation plan, include each payment as gross income to the extent that it exceeds the amount attributable to the value of the right to receive the payment on the decedent's date of death.

Revenue Ruling 75-437: An exempt charitable trust, established solely to provide college scholarships to county high school graduates, that is trusteed by an independent bank trustee, is a private foundation and not a supporting organization within the meaning of Code section 509(a)(3).

Revenue Ruling 75-436: An exempt charitable trust whose sole purpose is to grant scholarships to students graduating from the public high schools in a city and that is trusteed by the city council with its funds managed by the city treasurer is a supporting organization within the meaning of section 509(a)(3) of the Code and is not a private foundation.

Revenue Ruling 75-435: An exempt organization organized in a foreign country and receiving a substantial portion of its support from a foreign government is not a private foundation as defined in Code section 509(a).

Revenue Ruling 75-434: An organization established to provide temporary low-cost housing and related services for missionary families on furlough for recuperation or training in the U.S. from their assignments abroad is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-410: Audit fees paid by an exempt private foundation must be apportioned between its investment and exempt activities and only that portion of the fees attributable to the investment activities is deductible in computing the foundation's net investment income under Code section 4940(c).

Revenue Ruling 75-393: An award by a private foundation to the person who has written the best work of literary criticism during the preceding year, whether it is an article, essay, treatise, or book, is not a taxable expenditure within the meaning of Code section 4945(d)(3).

Revenue Ruling 75-392: Computation of the amount that may be excluded as reasonable cash balances used (or held for use) directly in carrying out the foundation's exempt purpose in determining a private foundation's minimum investment return under Code section 4942(a) and Treas. Reg. section 53.4942(a)-2(c)(3)(ii)(e).

Revenue Ruling 75-391: How to compute the initial tax on self-dealing under Code section 4941(a)(1) where the foundation and the self-dealer (disqualified person) do not have the same taxable year.

Revenue Ruling 75-387: Hospitals that receive blood from a nonprofit blood bank under an agreement making each hospital responsible for collecting payment for the blood and remitting the payments to the blood bank, and requiring the hospital to pay for the blood if it fails to collect from the patient, are acting as agents for the blood bank. These amounts the hospital collects are treated as received by the blood bank directly from patients in determining if it satisfies the one-third support test under Code section 509(a)(2)(A)(ii) as an organization not a private foundation.

Revenue Ruling 75-386: A nonprofit organization that contracts with a private firm to provide the community with security patrols assisted by guard dogs, works to improve public services, housing, and residential parking, and that publishes a newspaper distributed free of charge to all community residents and sponsors a community basketball league, holiday programs, and meetings of community residents is operated exclusively for the promotion of social welfare and qualifies for exemption under section 501(c)(4) of the Code.

Revenue Ruling 75-385: A nonprofit publicly-supported organization that operates a rural rest home to provide, at a nominal charge, two-week vacations for elderly poor people from nearby metropolitan areas qualifies for exemption as a charitable organization under section 501(c)(3) of the Code.

Revenue Ruling 75-384: A nonprofit organization formed to promote world peace and disarmament by nonviolent direct action and whose primary activity is sponsoring antiwar protest demonstrations in which demonstrators are urged to commit violations of local ordinances and breaches of public order does not qualify for exemption under Code section 501(c)(3) or 501(c)(4).

Revenue Ruling 75-336: The redemption of stock from a private foundation to the extent necessary for the foundation to avoid the excess business holdings tax under Code section 4943 is a sale or exchange not equivalent to a dividend under section 302(b)(1), and the proceeds will be taxed neither as investment income nor as distributed income.

Revenue Ruling 75-295: A nonprofit organization conducting programs of research, public information and education, and professional education and training with respect to a specific disease but not with the principal purpose of providing medical or hospital care does not qualify for the exemption from communications tax provided by Code section 4253(h).

Revenue Ruling 75-290: An organization applying for recognition of exemption under Code section 501(c)(3), whose existence as a corporation under the applicable state law begins on the date of the filing of its articles of incorporation in the appropriate State office, is considered organized on that filing date for purposes of applying the notice provisions of section 508(a).

Revenue Ruling 75-289: Private foundation that distributed all of its net assets to an organization that had been in existence for only 20 months nevertheless met the requirements for a nontaxable voluntary termination under section 507(b)(1)(A) where the distributee was a successor to two organizations that had been existence for the required continuous period of 60 calendar months prior to the distribution.

Revenue Ruling 75-288: The payment by an organization of law enforcement officers for its members' legal defense in actions brought against them in connection with the performance of their official duties does not adversely affect the exempt status of the organization under Code section 501(c)(5).

Revenue Ruling 75-287: A nonprofit organization whose members are involved in the commercial fishing industry in a state that publishes a monthly newspaper of commercial fishing technical information and news and that derives its income primarily from membership dues and sale of advertising does not qualify as an agricultural organization under Code section 501(c)(5) but may qualify as a business league under section 501(c)(6).

Revenue Ruling 75-286: A nonprofit organization with membership limited to the residents and business operators within a city block and formed to preserve and beautify the public areas in the block, thereby benefiting the community as a whole as well as enhancing members' property rights, will not qualify for exemption under Code section 501(c)(3) but may qualify under section 501(c)(4); Revenue Ruling 68-14 distinguished.

Revenue Ruling 75-285: A nonprofit organization formed to eliminate discrimination against members of minorities seeking employment in the construction trades by recruiting, educating, and counseling workers, providing technical assistance to attorneys involved in suits to enforce workers' rights, and acting as court-appointed monitor after successful suits, is organized and operated exclusively for charitable and educational purposes.

Revenue Ruling 75-284: A nonprofit organization that was formed to provide high school graduates and college students with work experience, for which they receive no compensation, in selected trades or professions, and that is financed by tuition and contributions from the general public, is an organization operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-283: An organization comprised of public housing tenant groups in a state and formed to promote the rights and welfare of public housing tenants by providing them with information and technical assistance regarding regulations and laws concerning public housing and acting as the state recognized agent for public housing tenant organizations qualifies for exemption as operated exclusively for charitable purposes.

Revenue Ruling 75-282: An organization formed and controlled by an exempt conference of churches that borrows funds from individuals and makes mortgage loans at less than the commercial rate of interest to affiliated churches to finance the construction of church buildings qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-270: Explaining legislative changes to the minimum investment return under Code section 4942 for private foundations organized before May 27, 1969.

Revenue Ruling 75-231: Organizations, including churches, that conduct schools with a policy of refusing to accept children from certain racial and ethnic groups will not be recognized as tax-exempt charities under Code sections 170 and 501(c)(3).

Revenue Ruling 75-215: An exempt organization maintaining a regular staff of paid instructors who conduct field study courses related to sociological and physical sciences for a regularly enrolled body of college and secondary school students supplementing their formal classroom studies is a nonprofit educational organization exempt from retailers, manufacturers, and communications excise taxes.

Revenue Ruling 75-211: A newly created organization that can reasonably be expected to meet the requirements of section 170(b)(1)(A)(vi) of the Code for its first three years of existence may receive a ruling or determination letter that it will be treated as a publicly supported organization even though its first taxable year consists of less than eight months.

Revenue Ruling 75-207: The value of an island, owned by a private foundation dedicated to preserving the natural ecosystems and historical and archaeological remains on the island that has no residential use and to which present access is limited to invited public and private researchers, may be excluded from the foundation's minimum investment return under Code section 4942(e).

Revenue Ruling 75-201: The sale of advertising by volunteers of an exempt organization, which raises funds for an exempt symphony orchestra and publishes an annual concert book distributed at the orchestra's annual charity ball, is not a business regularly carried on in determining unrelated income under Code section 512; Revenue Ruling 73-424 distinguished.

Revenue Ruling 75-200: The sale of advertising during a four-month period by paid employees of an exempt organization, which raises funds for an exempt symphony orchestra and publishes a weekly concert program distributed free at the symphony performances over an eight-month period, is a business regularly carried on in determining unrelated income under Code section 512.

Revenue Ruling 75-199: A nonprofit organization that restricts its membership to individuals of good moral character and health belonging to a particular ethnic group residing in a stated geographical area and provides sick benefits to members and death benefits to their beneficiaries is not exempt under Code section 501(c)(4) for tax years beginning after June 2, 1975; Revenue Ruling 55-495 modified.

Revenue Ruling 75-198: An organization that establishes a service center providing information, referral, counseling services relating to health, housing, finances, education, and employment, as well as a facility for specialized recreation for a particular community's senior citizens, who need not become members to obtain the services or participate in the activities, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 75-197: A nonprofit organization that operates a free computerized donor authorization retrieval system to facilitate transplantation of body organs upon a donor's death qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 75-196: An organization operating a law library whose rules limit access and use to members, or their designees, of a local bar association, composed of substantially all of the members of the legal profession in the municipality and providing the library's primary support, qualifies for exemption under Code section 501(c)(3) as an educational organization.

Revenue Ruling 75-38: A list of states that have adopted legislation satisfying the requirements of Code section 508(e), relating to the governing instruments of private foundations.

 


 

1974

 

Revenue Ruling 74-615: A nonprofit organization whose purpose is to educate the public about the accuracy and fairness of news coverage by local newspapers and, by educational methods, encourage the newspapers to meet high standards of journalism, qualifies for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-614: An otherwise exempt organization of exempt colleges and universities that devises, operates, and provides the organizational structure for a regional network of member owned or leased computers to collect and disseminate scientific and educational information to exempt members' faculties and students is operated exclusively for charitable purposes and exempt under Code section 501(c)(3).

Revenue Ruling 74-601: Reimbursement by a private foundation for travel, meals, and lodging expenses incurred by U.S. Congressmen it chooses to participate in a conference it cosponsors in a foreign country is not within the exception to self-dealing set forth in section 4941(d)(2)(B)(vii) of the Code.

Revenue Ruling 74-600: The placing of paintings owned by a private foundation in the residence of a substantial contributor, a disqualified person, is an act of self-dealing under section 4941(d)(1)(A) of the Code.

Revenue Ruling 74-596: An organization whose members are exempt labor unions representing public employees and which is primarily engaged in supporting litigation activities, proper for any one of its member unions, directed to the betterment of conditions for public employees, qualifies for exemption under section 501(c)(5) of the Code.

Revenue Ruling 74-595: An organization that provides free counseling to men concerning methods of voluntary sterilization, assists them in obtaining sterilization operations, and distributes pamphlets and brochures explaining the effectiveness of sterilization in family planning is exempt under section 501(c)(3) of the Code.

Revenue Ruling 74-591: A pension for past personal services paid by a private foundation to one of its directors, a disqualified person whose total compensation including the pension is not excessive, does not constitute an act of self-dealing under section 4941 of the Code.

Revenue Ruling 74-579: An exempt private foundation that obtained a loan from a commercial lending institution, made an interest-free temporary construction loan to an exempt university, made no attempt to collect the loan, and forgave a portion of it, may not deduct or otherwise take into account the interest it paid for its loan in computing its net investment income under section 4940(c) of the Code.

Revenue Ruling 74-575: A nonprofit organization that supervises the preparation and inspection of food products prepared commercially in a particular locality to ensure that they satisfy the dietary rules of a particular religions, thereby assisting the individual members of the religion to comply with its tenets and dictates, qualifies for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-574: An organization exempt under Code section 501(c)(3), operating a broadcasting station presenting religious, educational, and public interest programs, is not participating in political campaigns on behalf of public candidates in violation of the provisions of that section by providing reasonable air time equally available to all legally qualified candidates for election to public office in compliance with section 312(a)(7) of the Federal Communications Act of 1934 as amended and endorsing no candidate or viewpoint.

Revenue Ruling 74-572: An exempt organization that maintains a free clinic for animals does not qualify as a hospital or an organization that provides medical care or hospital care within the meaning of Code section 170(b)(1)(A)(iii), and is a private foundation.

Revenue Ruling 74-560: An amount recorded for depreciation on the books of a private foundation is not a qualifying distribution under Code section 4942(g)(1)(B), where the amounts was equal to the straight line depreciation for a fiscal year subsequent to 1970 on a building constructed for use directly in furtherance of purposes described in section 170(c)(2)(B).

Revenue Ruling 74-553: A nonprofit organization formed by members of a state medical association to operate peer review boards for the primary purpose of establishing and maintaining standards for quality, quantity, and reasonableness of costs of medical services qualifies for exemption from tax under Code section 501(c)(6) but not under section 501(c)(3).

Revenue Ruling 74-518: A nonprofit organization of dairy farmers, a member of the National Cooperative Dairy Herd Improvement Program sponsored by the U.S. Department of Agriculture, that derives its income form testing fees and membership assessments and that weights and tests milk of members' cows and makes statistic information based on the tests available to members, nonmembers, and governmental agencies for use in improving milk production is exempt as an agricultural organization under Code section 501(c)(5); Revenue Ruling 70-372 clarified and distinguished.

Revenue Ruling 74-498: A collection of paintings, owned by a private foundation formed to further the arts, that are loaned under an active loan program for exhibition in museums, universities, and similar institutes, are being used directly in carrying gout the foundation's exempt purposes within the meaning of Code section 4942(e)(1)(A), and the value of the paintings is excludable in computing the foundation's minimum investment return.

Revenue Ruling 74-497: The gross investment income of a nonexempt charitable trust described in Code section 4947(a)(1), for purposes of determining the excise tax on investment income under section 4940, does not include the trust's unrelated business income which is taxable under section 641(a).

Revenue Ruling 74-490: A corporation that remains in existence after terminating its private foundation status under Code section 507(b)(1)(A) must, unless specifically excepted by section 508(c), file an application for recognition of exemption if it wishes to be treated as an organization described in section 501(c)(3).

Revenue Ruling 74-489: A country club that issues corporate membership is dealing with the general public in the form of the corporations' employees. Gross receipts from such members will be a factor in determining whether the club qualifies as a social club under Code section 501(c)(7).

Revenue Ruling 74-488: The production of fish on privately-owned farms is an agricultural activity within the meaning of Code section 501(c)(5).

Revenue Ruling 74-487: The advance ruling period will be three years for a newly created publicly supported organization described in section 170(b)(1)(A)(vi) of the Code having a first taxable year consisting of more than seven but less than eight months.

Revenue Ruling 74-450: An operating private foundation's conversion of a portion of its newly acquired land into an extension of its existing wildlife sanctuary and the remainder into a public park under a four-year construction contract under which payments are mainly during the last two years constitutes a "specific project" and the foundation's set-aside of all its excess earnings for four years, for which it files a timely justifying application with the Service, will be treated as a qualifying distribution under section 4942(g)(2) of the Code, for each taxable year in which such earnings are set aside and remain unexpended.

Revenue Ruling 74-425: The wagering and occupational taxes imposed by sections 4401 and 4411 of the Code do not apply to activities of a nonprofit social club, exempt from income tax under section 501, involving the conduct of (1) a lottery in which participation is limited to members and the net proceeds are used to defray operating expenses or to offset losses incurred in the club's activities which are devoted exclusively to the pleasure and recreation of members, or (2) a Calcutta wagering pool in connection with a golf tournament for the pleasure and recreation of members and their guests, the proceeds from which are used primarily to pay the winners of the pool, with a portion retained by the clu8b to defray operating expenses.

Revenue Ruling 74-405: The payment of premiums by a private foundation for insurance indemnifying a disqualified person against liability for claims, in connection with his assistance in preparing a registration statement and prospectus for the foundation's public offering of stock issued by a corporation of which he was a principal officer, are treated as part of his compensation for such services and are not acts of self-dealing if the compensation is not excessive.

Revenue Ruling 74-404: Capital gain realized by an exempt private foundation from the sale of stock donated to it during its taxable years 1970 through 1972 and immediately disposed of upon receipt will not be taken into account for purposes of the tax on net investment income under section 4940(a) of the Code.

Revenue Ruling 74-403: For purposes of computing a private foundation's tax on net investment income under section 4940(a) of the Code, the net capital gain on the sale of a listed common stock purchased before December 31, 1969 is the difference between the selling price and the greater of (1) the foundation's basis in the stock, or (2) the mean average of the highest and lowest quotations on December 31, 1969, plus or minus subsequent adjustment to the date of sale.

Revenue Ruling 74-399: The operation of a dining room, cafeteria, and snack bar by an exempt art museum for use by the museum staff, employees, and members of the public visiting the museum is not an unrelated trade or business activity.

Revenue Ruling 74-368: Situations illustrating provisions of split-income trusts described in section 4947(a)(2) and 4947(b)(3) of the Code that meet the requirements of section 508(e).

Revenue Ruling 74-361: A nonprofit organization that was organized and operated as a volunteer fire company to provide fire protection and ambulance and rescue services to a community qualifies for exemption as a charitable organization under section 501(c)(3) of the Code and contributions to the organization are deductible under section 170. The organization may also qualify for exemption as a social welfare organization under section 501(c)(4). Further, under section 513(a)(1), conducting weekly public dances does not constitute an unrelated trade or business.

Revenue Ruling 74-316: The Service cannot issue a ruling that use of a proposed investment procedure by a private foundation will preclude imposition of tax under section 4944 of the Code.

Revenue Ruling 74-315: A private foundation that made a valid election to change its accounting period, which resulted in a short taxable year, and that had undistributed income at the end of its prior taxable year, must distribute the income before the close of the short taxable year to avoid the taxes imposed by section 4942 of the Code.

Revenue Ruling 74-308: A nonprofit organization whose principal activity is providing a telephone answering service to distribute calls for towing service on a rotational basis to its members who are tow truck owners and operators does not qualify for exemption under section 501(c)(6) of the Code.

Revenue Ruling 74-298: A nonprofit organization, whose membership is limited to local residents and whose sole activity is sponsoring an annual professional golf tournament for which it leases a golf course and charges admission, is not operated primarily for the promotion of social welfare and does not qualify for exemption under section 501(c)(4) of the Code.

Revenue Ruling 74-289: Although a charitable trust and an industrial corporation that benefited from the issuance of industrial development bonds are related persons within the meaning of Code section 267(b)(8), capital expenditures made by the trust with respect to its exempt activities in a municipality within three years before and after the date of the bond issuance will be considered capital expenditures within the meaning of section 103(c)(6)(D).

Revenue Ruling 74-287: Employees of a bank designated as the trustee of a private foundation, who have been delegated fiduciary responsibility for the day-to-day administration and distribution of the trust funds, are foundation managers within the meaning of section 4946(b)(1) of the Code and disqualified persons as defined in section 4946(a)(1)(B), even though they are ultimately responsible to the bank directors and officers for their actions with respect to the trust.

Revenue Ruling 74-281: Retired employees who were members of an association of employees at the time of retirement are employees within the meaning of section 501(c)(4) of the Code; thus, an otherwise qualifying local association of employees that admits to such individuals to membership qualifies for exemption under that section.

Revenue Ruling 74-246: An organization helping the police department apprehend and convict criminals by making funds available for use in offering rewards qualifies for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-229: An organization that is organized and operated to support a foreign, rather than a domestic, organization meeting the requirements of section 509(a)(1) and (a)(2) of the Code and that otherwise meets the requirements of section 509(a)(3), qualifies as an organization described in that section.

Revenue Ruling 74-228: A nonprofit organization, formed by carriers engaged in regular transoceanic passenger service, whose primary activity consists of appointing travel agents to book passenger travel on its members' ships, is performing particular services for its members and does not qualify for exemption under section 501(c)(6) of the Code.

Revenue Ruling 74-224: An exempt organization whose membership is composed of churches of different denominations qualifies as an association of churches within the meaning of section 170(b)(1)(A)(i) of the Code for purposes of classification as an organization that is not a "private foundation" within the meaning of section 509(a)(1).

Revenue Ruling 74-207: A resolution by a political subdivision, not qualifying as a "bond resolution," that authorizes an agreement obligating the political subdivision to construct and operate water pollution control facilities for use by an industrial corporation and the issuance of bonds by the political subdivision to finance the construction of such facilities constitutes "some other similar official action" within the meaning of Treas. Reg. § 1.103-8(a)(5)(iii).

Revenue Ruling 74-197: The investment by an exempt employees' trust in a partnership that was organized to invest in securities and borrows funds for that purpose may result in unrelated business taxable income to the extent its share of partnership income is derived from or on account of the debt-financed securities.

Revenue Ruling 74-196: To qualify as a mutual insurance company under section 501(c)(15) of the Code the following characteristics, while not conclusive, must be present: (1) the right of policyholders to be members to the exclusion of others and the right of such members to choose the management; (2) the sole business purpose is to supply insurance substantially at cost; (3) the right of members to the return of premiums in excess of those amounts needed to cover losses and expenses; and (4) common equitable ownership of the assets by the members.

Revenue Ruling 74-195: A nonprofit organization formed to manage, graze, and sell members' cattle is providing a direct business service to its members and does not qualify for exemption as an agricultural organization under section 501(c)(5) of the Code.

Revenue Ruling 74-194: A nonprofit organization formed to prevent overbreeding of cats and dogs, by providing funds to pet owners who wish to have their pets spayed or neutered but cannot afford the cost of such operations, qualifies for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-183: A Canadian private foundation, exempt under the Canadian income tax and exempt from U.S. income tax under section 501(c)(3) of the Code, is also exempt from the tax imposed on gross investment income by section 4948(a) by virtue of Article X of the U.S.-Canada income tax convention.

Revenue Ruling 74-168: A social club does not jeopardize its exemption under section 501(c)(7) of the Code by admitting corporation-sponsored individuals who have the same rights and privileges as regular individual members and who must be approved by the membership committee.

Revenue Ruling 74-167: Including some self-employed persons in the membership of a qualified labor organization does not affect the organization's exempt status under section 501(c)(5) of the Code.

Revenue Ruling 74-148: A nonprofit organization that conducts regular bowling tournaments for its members qualifies for exemption under section 501(c)(7) of the Code where its overall program is designed to effect a commingling of members for their pleasure and recreation. The awarding of cash prizes to tournament winners from tournament entry fees is not an inurement of net income to members.

Revenue Ruling 74-147: A nonprofit organization, whose members represent diversified businesses that own, rent, or lease digital computers produced by various manufacturers, organized to improve the efficiency of its members' use of computers, qualifies for exemption under section 501(c)(6) of the Code.

Revenue Ruling 74-146: A nonprofit organization of accredited educational institutions, whose membership includes a small number of proprietary schools, and whose activities include preparing accreditation standards, identifying schools and colleges meeting those standards, and disseminating accredited institution lists, qualifies as an exempt organization under section 501(c)(3) of the Code.

Revenue Ruling 74-125: Payments to consultants by a private foundation for personal services performed in developing model curricula and designing educational materials to help the foundation assist educators to employ improved educational methods are not grants within the meaning of section 4945(d)(3) of the Code.

Revenue Ruling 74-118: A nonprofit organization of farmers' wives, formed to improve the agricultural way of life in a state, qualifies for exemption under section 501(c)(5) of the Code.

Revenue Ruling 74-117: A nonprofit organization formed to implement an orderly change of administration of the office of governor of a state by helping the governor-elect, during the period between his election and inauguration, in screening and selecting applicants for state appointive offices and preparing a legislative message and program reflecting the party's platform and budget, is an action organization under Treas. Reg. § 1.501(c)(3)-1, and does not qualify for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-116: An organization whose membership is limited to organizations that own, rent, or use a specific type of computer and whose activities are designed to keep members informed of current scientific and technical data of special interest to them as users of the computer is not exempt under section 501(c)(3) of the Code.

Revenue Ruling 74-99: To qualify for exemption under section 501(c)(4) of the Code, a homeowners association (1) must serve a "community" which bears a reasonable recognizable relationship to an area ordinarily identified as governmental, (2) must not conduct activities directed to the exterior maintenance of private residences, and (3) the common areas or facilities it owns and maintains must be for the use and enjoyment of the general public.  Revenue Ruling 72-102  [link] modified.

Revenue Ruling 74-81: A nonprofit organization formed to promote the business welfare and interests of persons engaged in the contracting trade and related industries and whose principal activity is to provide its members with group workmen's compensation insurance is not entitled to exemption under section 501(c)(6) of the Code.

Revenue Ruling 74-38: Income derived by an association of law enforcement officials, exempt under Code section 501(c)(6), from selling space in its journal either for conventional advertising or merely to identify the purchasing organization without a further advertising message, is unrelated trade or business income under section 513 of the Code.

Revenue Ruling 74-30: A flying club of limited membership that provides flying privileges solely for its members, assesses dues based on the club's fixed operating costs and charges based on variable operating expenses, and whose members are interested in flying as a hobby, constantly commingle in informal meetings, maintain and repair the aircraft owned by the club, and fly together in small groups, qualifies for exemption under section 501(c)(7) of the Code.

Revenue Ruling 74-18: An association formed by a corporation to provide worker's compensation benefits the corporation was already obligated to pay under state law does not qualify for exemption under Code section 501(c)(9).

Revenue Ruling 74-17: An organization formed by unit owners of a condominium housing project to provide for the management, maintenance, and care of the common areas of the project, as defined by state statute, with membership assessments paid by the unit owners, does not qualify for exemption under section 501(c)(4) of the Code.

Revenue Ruling 74-16: An organization formed to help individuals in developing nations improve their living conditions through educational programs on credit problems and to instruct and train individuals from those nations in techniques of organizing and managing credit unions qualifies for exemption as an educational organization under section 501(c)(3) of the Code.

Revenue Ruling 74-15: A public library organized as a separate entity under a state statute, without power to impose taxes for its operation but whose funds are obtained by certifying a tax rate needed for its operation to the rate-making authority, qualifies for exemption under section 501(c)(3) of the Code.

Revenue Ruling 74-14: A public housing authority incorporated under a state statute conferring upon it the power to conduct examinations and investigations, to administer oaths, issue subpoenas, and make its findings and recommendations available to appropriate agencies, does not qualify for exemption under section 501(c)(3) of the Code.

 


 

1973

 

Revenue Ruling 73-613: Payment by a private foundation of legal fees awarded by a court to counsel for its director-manager, a disqualified person, who had filed suit against the remaining directors to require them to carry on the foundation's charitable program, is not an act of self-dealing.

Revenue Ruling 73-595: A private foundation's deposit of funds in a savings account with a disqualified banking institution on the tenth day of a calendar quarter and withdrawal of the funds before the end of the next quarter, thereby subjecting itself to a loss of interest for the deposit period, is self-dealing under section 4941(d)(1)(B) of the Code.

Revenue Ruling 73-587: Income derived by an exempt organization, organized and operated for the prevention of cruelty to animals, from providing pet boarding and grooming services for the general public is income from unrelated trade or business under section 513 of the Code.

Revenue Ruling 73-577: The unrelated business income tax shown on a Form 990-T by a corporate taxpayer with respect to which the period of limitations has already expired can be used in determining the amount of a deficiency of the corporation when it is no longer recognized as an exempt organization where an extension of the period of limitations was obtained in connection with its Form 990.

Revenue Ruling 73-571: Effect on exempt status of a charitable remainder unitrust of investing in bank common trust funds.

Revenue Ruling 73-569: An organization that provides free counseling to women on methods of resolving unwanted pregnancies, including lawful abortion, delivering and placing the child for adoption, and delivering and keeping the child, qualifies for exemption as an educational organization under section 501(c)(3) of the Code.

Revenue Ruling 73-567: A medical specialty board that devises and administers written examinations to physicians in a medical specialty and issues certificates to successful candidates is exempt as a business league under section 501(c)(6) of the Code, but is not exempt under section 501(c)(3).

Revenue Ruling 73-546: The payment by a private foundation to a bank, a disqualified person, of a service fee, for an overdrawn checking account, equal to the actual cost of processing the overdraft, is not self-dealing under section 4941 of the Code.

Revenue Ruling 73-543:  An organization established to educate persons in a method of natural childbirth that as its primary activity operates a school offering courses to educate prospective parents and train medical professionals, and that meets the requirements relating to faculty, curriculum, and enrolled student body, is a nonprofit educational organization exempt from the retailers, manufacturers, and communication taxes.

Revenue Ruling 73-520: A club that promotes and protects a particular breed of dog not raised or used by members as farm animals is not exempt as an agricultural organization under section 501(c)(5) of the Code, but may qualify for exemption as a social club under section 501(c)(7).

Revenue Ruling 73-504: An organization formed before October 9, 1969, is not precluded from classification as other than a private foundation merely because it failed to notify the Service, as required by Code section 508(b), that it is not a private foundation by the March 22, 1973, deadline in the regulations; its status as other than a private foundation may be established by submitting a request for a determination letter.

Revenue Ruling 73-456: A training center established to instruct the blind to function properly with the aid of guide dogs qualifies as a nonprofit educational organization for purposes of the exemption from the retailers, manufacturers, and communications taxes.

Revenue Ruling 73-455: A nonexempt charitable trust described in section 4947(a)(1) of the Code that has made contributions to a private foundation exceeding the limitation in section 507(d)(2) is not a substantial contributor within the meaning of that section for purposes of the tax on self-dealing under section 4941.  The exception in section 1.507-6(a)(2) of the regulations for section 501(c)(3) organizations also applies to nonexempt charitable trusts.

Revenue Ruling 73-454: An organization that owns, operates, and maintains a cemetery for pets does not qualify for exemption under section 501(c)(13) of the Code.

Revenue Ruling 73-452: An organization created under state statute to pay claims against insolvent fire and casualty insurance companies qualifies for exemption as a business league under section 501(c)(6) of the Code where membership in the organization is required of all insurance companies writing fire and casualty insurance in the state and its income is derived from membership assessments and claims against the assets of the insolvent companies.

Revenue Ruling 73-440: A nonprofit organization that attempts to influence and advocates changes in the laws of a foreign country is an action organization within the meaning of Treas. Reg. § 1.501(c)(3)-1(c)(3), and therefore does not qualify for exemption from tax under section 501(c)(3) of the Code.

Revenue Ruling 73-439: An organization that selects its membership from the junior class of a college primarily based on compatibility without regard to scholarship, and that holds closed meetings at which the speaker-members conduct personally oriented speeches and discussions, is not operated for exclusively educational purposes and does not qualify for exemption under section 501(c)(3) of the Code.

Revenue Ruling 73-434: An organization exempt under section 501(c)(3) of the Code that has full-time instructors who regularly conduct a 26-day survival course, mostly out-of-doors, to teach young people how to survive in a natural environment, is an educational organization under section 170(b)(1)(A)(ii) and therefore not a private foundation.

Revenue Ruling 73-424: Income an exempt organization derived from the sale of advertising in its annual yearbook is unrelated business taxable income where an independent commercial firm under a contract covering a calendar year conducts an intensive advertising solicitation campaign in the organization's name and is paid a percentage of the gross advertising receipts for selling the advertising, collecting from advertisers, and printing the yearbook.

Revenue Ruling 73-422: In determining if an incorporated organization meets the time requirement in Treas. Reg. §§ 1.170A-9(e)(4)(vi) and 1.509(a)-(3)(c)(1)(iv) to entitle it to a ruling on whether it is publicly supported, the time a predecessor unincorporated association operated will be considered if incorporation has been the only significant change in the organization.

Revenue Ruling 73-411: A shopping center merchants' association whose membership is restricted to and required of the tenants of a one-owner shopping center and their common lessor, and whose activities are directed to promoting the general business interests of its members, does not qualify as a business league or chamber of commerce under section 501(c)(6) of the Code. Revenue Ruling 64-315 clarified.

Revenue Ruling 73-407: A contribution by a private foundation to a public charity made on the condition that the public charity change its name to that of a substantial contributor to the foundation and agree not to change the name again for 100 years is not self-dealing under section 4941(d)(1)(E) of the Code.

Revenue Ruling 73-386: An exempt business league that provides job injury histories on prospective employees from public state workers' compensation records to business concerns on an expedite basis for a fee is engaged in an unrelated trade or business.

Revenue Ruling 73-370: A nonprofit subordinate organization, formed and chartered by a local lodge of a fraternal beneficiary society exempt under section 501(c)(10) of the Code to carry on the fraternal and charitable activities of the society in a geographical area, is also exempt under section 501(c)(10).

Revenue Ruling 73-364: In determining whether the gross receipts of a local lodge of a tax-exempt fraternal beneficiary society are not more than $5,000 and whether it is excepted by section 6033(a)(2)(A)(ii) of the Code, from the requirements to file annual returns, insurance premiums collected from its members, maintained separately without use or benefit, and remitted to its parent organization which issued the insurance contracts are not gross receipts of the local lodge.

Revenue Ruling 73-363: The rental of a charter aircraft by a disqualified person, the charter aircraft company, to a private foundation is an act of self-dealing under section 4941(d)(1)(C) of the Code.

Revenue Ruling 73-349: An organization formed to purchase groceries for its membership at the lowest possible prices on a cooperative basis is not exempt as a social welfare organization under section 501(c)(4) of the Code.

Revenue Ruling 73-313: An organization formed and supported by residents of an isolated rural community to provide a medical building and facilities at reasonable rent to attract a doctor who would provide medical services to the entire community is exempt under section 501(c)(3) of the Code.

Revenue Ruling 73-307: An amendment to a supplemental unemployment benefit plan trust permitting an employee to authorize the trustee to deduct and pay union dues from his benefit payments will not adversely affect the qualification of the plan under section 501(c)(17) of the Code.

Revenue Ruling 73-306: A nonprofit organization formed to represent member-tenants of an apartment complex in negotiations with landlords, in litigation, and before local and Federal regulatory agencies on matters of mutual concern to the tenants does not qualify for exemption under section 501(c)(4) of the Code.

Revenue Ruling 73-285: An organization that provides funds to defend members of a religious sect in legal actions involving substantial constitutional issues of state abridgement of religious freedom is exempt under section 501(c)(3) of the Code.

Revenue Ruling 73-193: Patent development and management service fees deducted from royalties collected from licensees by an exempt charitable organization and distributed to the beneficial owners of the patents is not within the exception for royalties provided by Code section 512(b) in determining unrelated business taxable income.

Revenue Ruling 73-192: An organization whose sole activity is to provide life, sick, and accident benefits for members of a fraternal beneficiary society operating under the lodge system may qualify for exemption under section 501(c)(8) of the Code.

Revenue Ruling 73-165: A fraternal beneficiary society operating under the lodge system and providing for member benefit payments may qualify for exemption under section 501(c)(8) of the Code regardless of whether fraternal or insurance features predominate, as long as both features are present.

Revenue Ruling 73-164: A church-controlled commercial printing corporation whose business earnings are paid periodically to the church, but which has no other significant charitable activity, is a feeder organization under Code section 502 and does not qualify for exemption under section 501(c)(3).

Revenue Ruling 73-128: An organization that is otherwise qualified for exemption under Code section 501(c)(3) will not fail to qualify merely because it conducts its education and vocational training of unemployed and under-employed individuals by manufacturing and selling toy products.

Revenue Ruling 73-127: A nonprofit organization that operates a cut-price retail grocery outlet and allocates a small portion of its earnings to provide on-the-job training to the hard-core unemployed does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 73-126: An exempt organization's payment of reasonable pensions to retired employees at the discretion of its board of directors does not adversely affect its exempt status under Code section 501(c)(3).

Revenue Ruling 73-105: The sale of scientific books and city souvenirs by a museum of folk art exempt under Code section 501(c)(3) is unrelated trade or business even though other items sold in the museum shop are related to its exempt function.

Revenue Ruling 73-104: The sale of greeting card reproductions of art works by an art museum exempt under Code section 501(c)(3) is not unrelated trade or business.

Revenue Ruling 73-45: A nonprofit organization created to foster the development in a community of an appreciation for drama and musical arts by sponsoring professional presentations qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 73-14: Contributions to an endowment fund created by an exempt war veterans organization to care for disabled war veterans, some of whom are members of the organization, may be deducted as charitable contributions under Internal Revenue Code section 170.

 


 

1972

 

Revenue Ruling 72-560: An organization formed to educate the public about environmental deterioration due to solid waste pollution and operated with contributions and proceeds from the sale of collected solid waste for recycling is exempt under Code section 501(c)(3).

Revenue Ruling 72-559: An organization formed to provide substantial free legal services to low income residents of economically depressed communities by subsidizing recent law graduates who have been admitted to the bar is exempt under Code section 501(c)(3).

Revenue Ruling 72-513: The provision of facilities and faculty advisors for a campus newspaper that publishes the students' editorial opinions on political and legislative matters is not an attempt by the university to influence legislation or participate in political campaigns.

Revenue Ruling 72-512: A university is not participating in political campaigns within the meaning of Code section 501(c)(3) by providing a political science course that requires the students' participation in political campaigns of candidates of their choice.

Revenue Ruling 72-431: The regular sale of membership mailing lists by an exempt educational organization is unrelated trade or business under Code section 513.

Revenue Ruling 72-430: An organization that provides an elementary education for children may meet the requirements for an educational organization even though it has no formal course program or formal classroom instruction, and, therefore, is not considered a private foundation.

Revenue Ruling 72-391: An organization of farmers formed to furnish farm laborers for individual farmers does not qualify for exemption under Code section 501(c)(5).

Revenue Ruling 72-369: An organization formed to provide managerial and consulting services at cost to unrelated exempt organizations does not qualify for exemption under Code section 501(c)(3); Revenue Ruling 71-529 distinguished.

Revenue Ruling 72-244: A foreign tax-exempt organization may claim an exemption from withholding of tax on bond interest coupons presented for payment in the United States but will be subject to withholding for any taxable year in which the organization is a private foundation; Revenue Ruling 70-570 superseded.

Revenue Ruling 72-228: An organization formed to promote equal rights for women by investigating instances of discrimination in employment and to aid women in recognizing and dealing with discrimination qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 72-211: An organization formed to promote the interests of its members and persons or firms related to the building and construction industry by providing a plan room and news bulletin available to the entire industry qualifies for an exemption under Code section 501(c)(6); Revenue Ruling 56-65 clarified.

Revenue Ruling 72-209: A nonprofit organization formed to provide low-cost home health care for people of a community may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 72-147: An organization formed to provide low income housing to families but giving preference for housing to employees of a farm proprietorship operated by the individual who created and controls the organization does not qualify for exemption under section 501(c)(3) of the Code.

Revenue Ruling 72-124: Requirements that homes for the aged must meet to qualify for exemption under Code section 501(c)(3).

Revenue Ruling 72-102: A nonprofit organization formed to preserve the appearance of a housing development and to maintain streets, sidewalks, and common areas for use of the residents is exempt under Code section 501(c)(4); however, contributions to the organization are not deductible under Code section 170; modified Revenue Ruling 74-99.

Revenue Ruling 72-101: A nonprofit organization created through collective bargaining agreements to train individuals wanting to acquire skills in an industry is exempt under Code section 501(c)(3); it is also an educational organization described in section 170(b)(1)(A)(ii) and therefore not a private foundation under section 509(a).

Revenue Ruling 72-36: Certain requirements that cooperative companies must meet for exemption under Code section 501(c)(12) are explained.

Revenue Ruling 72-17: The exempt status of a cemetery company under Code section 501(c)(13) is not adversely affected if it sells monuments, markers, vaults, and flowers solely for use in the cemetery and uses the sales proceeds to maintain the cemetery.

Revenue Ruling 72-16: An organization providing a residential facility and therapeutic group living program for individuals recently released from a mental institution qualifies for exemption under Internal Revenue Code section 501(c)(3).

 


 

1971

 

Revenue Ruling 71-581: Operation of a separately incorporated thrift shop to raise funds for a group of specified exempt organizations may qualify for exemption under Code section 501(c)(3); Revenue Ruling 68-439 revoked.

Revenue Ruling 71-580: A nonprofit organization formed to compile genealogical research data on its family members in order to perform religious ordinances in accordance with the precepts of the religious denomination to which family members belong is exempt under Code section 501(c)(3).

Revenue Ruling 71-554: A charitable organization supported primarily by contributions from a community chest must file information returns for years beginning under 1969, unless excepted from filing under Code section 6033(a)(2); Revenue Ruling 67-271 superseded.

Revenue Ruling 71-544: A nonprofit corporation formed to hold title to securities and turn over its income to a selected exempt organization that has no control over the corporation is not an exempt title-holding corporation under Code section 501(c)(2).

Revenue Ruling 71-530: A nonprofit organization formed to represent the public interest at legislative and administrative hearings on tax matters qualifies for exemption under Code section 501(c)(4); contributions to the organization are not deductible as charitable contributions.

Revenue Ruling 71-529: A nonprofit organization that provides assistance in the management of participating colleges' and universities' endowment or investment funds for a charge substantially below cost qualifies for exemption under Code section 501(c)(3); distinguished Revenue Ruling 72-369.

Revenue Ruling 71-506: An engineering society formed to engage in scientific research in the areas of heating, ventilating, and air conditioning for the benefit of the general public qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 71-505: A city bar association, exempt under Code section 501(c)(6), that primarily directs its activities to the promotion and protection of the practice of law may not be reclassified as an educational or charitable organization exempt under section 501(c)(3).

Revenue Ruling 71-504: A city medical society, exempt under Code section 501(c)(6), that primarily directs its activities to the promotion of the common business purposes of its members may not be reclassified as an educational or charitable organization under section 501(c)(3).

Revenue Ruling 71-460: A domestic corporation that conducts a part or all of its charitable activities in a foreign country is not precluded from exemption under Code section 501(c)(3).

Revenue Ruling 71-447: A private school that does not have a racially nondiscriminatory policy as to students does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 71-421: A dog club, exempt under Code section 501(c)(7), formed to promote the ownership and training of purebred dogs and conducting obedience training classes, may not be reclassified as an educational organization exempt under section 501(c)(3).

Revenue Ruling 71-413: A nonprofit organization acting as a clearinghouse and course coordinator by bringing together instructors and interested students in a community for purposes of instruction is exempt under Code section 501(c)(3).

Revenue Ruling 71-395: A cooperative art gallery formed and operated by a group of artists for the purpose of exhibiting and selling their works does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 71-245: The time for filing Form 990-T for a taxable year ending December 31, 1970, January 31, 1971, or February 28, 1971, by social clubs and voluntary employees beneficiary associations with unrelated business income is extended to June 15, 1971; Revenue Rulings 71-219 and 71-238 modified.

Revenue Ruling 71-238: Social clubs with unrelated business income for a taxable year ending on December 31, 1970, or during January 1971, are granted an extension until May 15, 1971, to file Form 990-T; however, interest will not be waived; modified Revenue Ruling 71-245.

Revenue Ruling 71-219: The time for filing Form 990-T, Exempt Organization Business Income Tax Return, by voluntary employees' beneficiary associations with unrelated business income is extended; modified Revenue Ruling 71-245.

Revenue Ruling 71-175: A nonprofit organization that operates a telephone answering service for member doctors as its principal activity is not exempt under Code section 501(c)(6).

Revenue Ruling 71-156: An amendment to a supplemental unemployment benefit plan providing for the distribution to employees of funds representing contributions in excess of funding needed adversely affects the trust's exempt status under Code section 501(c)(17).

Revenue Ruling 71-155: A nonprofit association of licensed insurance companies that make insurance available to persons in high risk categories who cannot otherwise obtain coverage qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 71-99: A nonprofit organization formed to provide food and drink to firemen, policemen, and other authorized personnel at the scene of major disasters qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 71-97: A national honor society for women, formed to recognize scholastic achievements and to serve universities and colleges where chapters are established, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 71-29: A grant to a city transit authority to maintain a mass transportation system is a charitable disbursement furthering a section 501(c)(3) organization's exempt purposes.

 


 

1970

 

Revenue Ruling 70-641: A nonprofit organization of individuals from various professions in the field of public health and welfare, organized to develop greater efficiency in the professions and solve common problems, qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 70-640: A nonprofit organization providing personal marriage counseling services and conducting workshops and seminars about marital adjustment qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 70-591: A nonprofit organization of commercial banks formed to provide and promote a credit card plan for member banks does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 70-590: A nonprofit organization operating a clinic to aid victims of mind-affecting drugs and providing information about such drugs qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 70-585: Nonprofit housing organizations created to aid low and moderate income families by lessening neighborhood tensions, eliminating prejudice and discrimination, and combating community deterioration may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 70-536: An amendment to a supplemental unemployment benefit trust permitting low-risk income-producing investments that serve social purposes, do not accrue for the benefit of related parties, and are not contrary to employees' interests, will not affect the exempt status of the trust under Code section 501(c)(17).

Revenue Ruling 70-533: An educational day care center operated in conjunction with an industrial company that enrolls children based on family financial need and the child's needs for the center's care and development program is exempt under Code section 501(c)(3).

Revenue Ruling 70-449: A section 501(c)(3) organization is not engaged in prohibited legislative activity if, at the request of a legislative committee, a representative testifies as an expert witness on pending legislation affecting the organization.

Revenue Ruling 70-372: An organization of agricultural producers formed to process individual farmers' milk production records for use in improving milk production does not qualify for exemption under Code section 501(c)(5). Modified Revenue Ruling 74-518.

Revenue Ruling 70-132: An exempt employees' pension trust does not incur business lease indebtedness under Code section 514(c) when it purchases land free of mortgage indebtedness and executes a 40-year lease to an unrelated partnership that mortgages its leasehold interest.

Revenue Ruling 70-130: A cooperative telephone company deriving more than 85 percent of its income from members is exempt under Code section 501(c)(12) notwithstanding that nonmembers are charged a higher rate for service than the members.

Revenue Ruling 70-129: An organization formed to support research in anthropology by manufacturing quality cast reproductions of anthropological specimens which are sold to scholars and educational institutions in a noncommercial manner qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 70-95: Leases of real property by an exempt agricultural organization to its taxable subsidiaries for purposes not substantially related to the organization's exempt function are businesses leases within the meaning of section 514 of the Internal Revenue Code.

Revenue Ruling 70-81: The exempt status of a chamber of commerce under Code section 501(c)(6) is not adversely affected by the development of an industrial park to attract new industry to the community.

Revenue Ruling 70-80: A nonprofit trade association of manufacturers whose principal activity is promoting its members' products under the association's registered trademark does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 70-79: A nonprofit organization assisting local governments of a metropolitan area by conducting research to develop solutions for common regional problems, but not advocating any legislative action to implement its findings, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 70-48: A social club whose active members pay substantially lower dues and initiation fees than associate members, although both classes enjoy rights and privileges in the club facilities, does not qualify for exemption under Code section 501(c)(7).

Revenue Ruling 70-32: A flying club providing economical flying facilities for members but having no organized social and recreational program does not qualify for exemption under Code section 501(c)(7).

Revenue Ruling 70-31: A nonprofit trust created by an agreement between a labor union and a businesses league is an association of persons having some common business interest and is exempt under Code section 501(c)(6).

Revenue Ruling 70-4: An organization that promotes and regulates a sport for amateurs is not exempt under section 501(c)(3) of the Internal Revenue Code but is exempt under section 501(c)(4).

 


 

1969

 

Revenue Ruling 69-637: The exemption of a cemetery company under Code section 501(c)(13) is adversely affect by engaging in the operation of a crematorium.

Revenue Ruling 69-636: The exempt status of a country club under Code section 501(c)(7) will not be adversely affected if it makes its facilities available to an exempt organization for charitable fund-raising activities at a charge equal to or less than direct cost.

Revenue Ruling 69-635: An automobile club whose principal activity is rendering automobile services to its members but has no significant social activities does not qualify for exemption under Code section 501(c)(7).

Revenue Ruling 69-633: Answers to questions involving the tax exempt status of (1) hospitals that establish a cooperative hospital laundry service; and (2) a hospital that establishes its own laundry facilities and sells service to other hospitals.

Revenue Ruling 69-632: A nonprofit organization composed of members of a particular industry to develop new and improved uses for existing products of the industry is not exempt under Code section 501(c)(3) but may qualify for exemption under section 501(c)(6).

Revenue Ruling 69-631: A nonprofit organization formed by a medical staff of an exempt hospital to carry on a charitable program of benefit to the hospital qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 69-574: The passive receipt of income by an exempt employees' trust from installment notes purchased from the employer-settlor is not unrelated business taxable income under Code section 512.

Revenue Ruling 69-573: A college fraternity that maintains a chapter house for active members who are students of the school is not exempt under Code section 501(c)(3), but is exempt under section 501(c)(7). Contributions to the fraternity are not deductible.

Revenue Ruling 69-572: A nonprofit organization, created to construct and maintain a building for the exclusive purpose of housing and serving exempt member agencies of a community chest, may be exempt under Code section 501(c)(3). Revenue Ruling 58-547 distinguished.

Revenue Ruling 69-545: Examples illustrate whether a nonprofit hospital claiming exemption under Code section 501(c)(3) is operated to serve a public rather than a private interest. Revenue Ruling 56-185 modified.

Revenue Ruling 69-538: An organization that operates a college book and supply store serving exclusively members of the faculty and student body and refunds its excess earnings to member purchasers qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 69-528: An organization regularly carrying on an investment service business that would be an unrelated trade or business if carried on by any of the exempt organizations on whose behalf it operates, is not exempt under Code section 501(a).

Revenue Ruling 69-527: A social club formed to assist its members in their business endeavors through study and discussion of problems and other activities at weekly luncheon meetings does not qualify for exemption under Code section 501(c)(7).

Revenue Ruling 69-526: A nonprofit organization formed by a group of physicians specializing in heart disease to research the cause and to publish treatments of heart defects qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 69-492: The additional ten-percent charitable deduction applies to contributions made to an organization whose only function is to conduct classes for eight weeks each summer during which it maintains a regular faculty and curriculum with a regularly enrolled body of students; the organization is a school within the meaning of section 170(b)(1)(A)(ii).

Revenue Ruling 69-464: Leases of office space by an exempt hospital to members of its medical staff who contribute importantly to the performance of hospital functions are not considered business leases within the meaning of Code section 514.

Revenue Ruling 69-463: The leasing of its adjacent office building, and the furnishing of certain office services, by an exempt hospital to a hospital-based medical group is not unrelated trade or business under Code section 513.

Revenue Ruling 69-441: A nonprofit organization formed to help reduce personal bankruptcy by informing the public on personal money management and aiding low-income individuals and families with financial problems is exempt under Code section 501(c)(3).

Revenue Ruling 69-430: Income from publishing and selling a book by an exempt organization is unrelated business income; however, if it transfers its publication rights to a commercial publisher, royalty income received is not unrelated business income.

Revenue Ruling 69-400: A nonprofit organization that selects students and faculty members who are interested in a particular foreign history and culture and enrolls them at foreign universities qualifies for exemption under Code section 501(c)(3); Revenue Ruling 67-237 distinguished.

Revenue Ruling 69-387: A nonprofit organization composed of advertising agencies, which verifies the advertising claims of publications selling advertising space and makes reports available to members of the advertising industry generally, qualifies for exemption under Code section 501(c)(6).

Revenue Ruling 69-386: A company, even though formed to provide employment to members of a certain labor union to which the company pays all of the profits from its business operation, is not exempt under Code section 501(c)(5).

Revenue Ruling 69-385: A community welfare corporation that purchases and sells unimproved land and engages in other business activities, the profits form which are distributed to members, is not exempt under Code section 501(c)(4).

Revenue Ruling 69-384: An organization created to maintain an amateur baseball association made up of baseball teams with amateur players of college age is exempt under Code section 501(c)(4).

Revenue Ruling 69-383: The exempt status of a hospital will not be jeopardized when, after arm's length negotiations, it enters into an agreement with a hospital-based radiologist to compensate him on the basis of a fixed percentage of the departmental income.

Revenue Ruling 69-381: A title-holding corporation that derives income from renting real property to the general public is not precluded from exemption under Code section 501(c)(2).

Revenue Ruling 69-283: An organization formed by a group of individuals at a United States military base in a foreign country, which meets all but the territorial requirements of the Federal Credit Union Act, will be regarded as a credit union for purposes of Code section 501(c)(14)(A).

Revenue Ruling 69-282: An organization must be formed and operate under the state law governing the formation of credit unions to qualify under section 501(c)(14)(A) of the Code as a state chartered credit union.

Revenue Ruling 69-281: A social club providing exclusive and automatic membership to home owners in a housing development, with no part of its earnings inuring to the benefit of any member, may qualify for exemption under Code section 501(c)(7).

Revenue Ruling 69-280: A nonprofit organization formed to maintain exterior walls and roofs of homes of members who own houses in a development is not exempt as a social welfare organization under Code section 501(c)(4).

Revenue Ruling 69-279: An irrevocable inter vivos trust which provides that a fixed percent of the income must be paid annually to the settlor with the balance to charity is not organized and operated exclusively for charitable purposes and is not exempt under Code section 501(c)(3).

Revenue Ruling 69-278: A title holding corporation renting a building and trucks under separate unrelated leases to exempt fraternal beneficiary societies is engaged in the business of renting personal property independent of real property and is not exempt under Code section 501(c)(2).

Revenue Ruling 69-269: The operation of a parking lot for patients and visitors only by a section 501(c)(3) hospital is not unrelated trade or business under Code section 513.

Revenue Ruling 69-268: Operating a cafeteria and coffee shop, primarily for employees and medical staff, by a section 501(c)(3) hospital, is not unrelated trade or business under Code section 513.

Revenue Ruling 69-267: Operating a gift shop, patronized by patients, visitors making purchases for patients, and employees, by a section 501(c)(3) hospital, is not unrelated trade or business under Code section 513.

Revenue Ruling 69-266: An organization informed and controlled by a doctor of medicine, hired to conduct research programs consisting of examining and treating patients who are charted the prevailing fees for services rendered, is not exempt under Code section 501(c)(3).

Revenue Ruling 69-257: A nonprofit organization awarding scholarships based on scholastic ability, without regard to financial need, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 69-256: A testamentary test established to make annual payments to exempt charitable organizations and to use a fixed sum from annual income for the perpetual care of the testator's burial lot is not exempt under Code section 501(c)(3).

Revenue Ruling 69-247: Filing a Form 990 series return, which discloses sufficient facts to apprise the Service of the potential existence of unrelated business taxable income, commences the running of the period of limitations on assessment; modifying Revenue Ruling 62-10.

Revenue Ruling 69-232: Three situations illustrate the application of certain concepts in determining the effect of selling property on the exempt status of a section 501(c)(7) social club.

Revenue Ruling 69-220: A social club that receives a substantial portion of its income from the renting property and uses that income to defray operating expenses and improve and expand its facilities is not exempt under Code section 501(c)(7).

Revenue Ruling 69-219: A social club that regularly holds its golf course open to the general public, charging green fees that are used to maintain and improve club facilities, is not exempt under Code section 501(c)(7).

Revenue Ruling 69-179: An exempt organization's income from a mineral interest is not a royalty excluded in computing unrelated business taxable income by Code section 512(b)(2) where the organization is liable for the operating expenses associated with its interest.

Revenue Ruling 69-178: Income an exempt organization derives for the occasional use of its meeting hall is rents from real property within the meaning of Code section 512(b)(3) and is excluded in determining unrelated business taxable income.

Revenue Ruling 69-177: An organization wholly owned by a tax-exempt college that manufactures and sells wood products primarily to employ students of the college to enable them to continue their education does not qualify for exemption under section 501(c)(3) of the Code.

Revenue Ruling 69-176: The exempt status of a section 501(c)(3) organization is not affected by accepting an income-producing asset subject to a reserved life estate in the transferor or in exchange for an annuity specifically charged against the asset.

Revenue Ruling 69-175: A nonprofit organization, formed by parents of pupils attending a private school, that provides bus transportation for members' children serves a public rather than a public interest and does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 69-174: A nonprofit organization formed to provide free rescue and emergency services to distressed persons may be exempt under Code section 501(c)(3).

Revenue Ruling 69-162: The Service will review mineral property transfers by exempt organizations to controlled corporations and will characterize payments according to the substance of the transaction regardless of its form; the Robert A. Welch Foundation decision (334 F.2d 774 (1964)) will not be followed.

Revenue Ruling 69-161: A nonprofit legal aid society providing free legal services to indigent persons otherwise financially incapable of obtaining such services qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 69-106: A nonprofit manufacturers' organization that conducts research in projects of common interest to an industry and makes the results available only to members rather than to the industry as a whole does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 69-69: A section 501(c)(3) arts organization's leasing studio apartments and operating a dining hall are unrelated trades or businesses where occupancy in the apartments is not primarily for the convenience of its members.

Revenue Ruling 69-68: A nonprofit club may operate gaming devices for the pleasure of its members and guests without affecting its section 501(c)(7) exempt status, even though operating gaming devices is illegal under local law.

Revenue Ruling 69-51: Selling cattle for its members on a commission basis by a section 501(c)(5) agricultural organization is an unrelated trade or business under Code section 513.

Revenue Ruling 69-39: A charitable organization's exemption from tax under Internal Revenue Code section 501(c)(3) was not affected by purchasing securities from its creator (its sole trustee) at the price he paid for them and reselling them at a profit.

Revenue Ruling 69-21: Where an exempt organization purchases a baseball pool, retaining the seller to operate the pool, the organization and the operator are jointly and severally liable for the tax on wagers and the occupational tax.

 


 

1968

 

Revenue Ruling 68-657: The section 501(c)(6) exempt status of a business league is not affected where it distributes forms that are designed primarily for use by the members in reporting data to the league, but are also used by members as business records.

Revenue Ruling 68-656: An organization that informs the public on controversial subjects and attempts to influence legislation germane to its program may qualify for exemption under Code section 501(c)(4).

Revenue Ruling 68-655: A nonprofit organization formed to promote racial integration in housing, to lessen neighborhood tensions, and to prevent deterioration of neighborhoods, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 68-639: The section 501(c)(7) exempt status of a social club will not be adversely affected where it redeems certain members' stock at the book value of the shares at the time of redemption, even though the stockholder realizes gain.

Revenue Ruling 68-638: A country club that annually hosts a golf tournament to which the general public is admitted for a charge and uses the net income therefrom for club purposes does not qualify for exemption under Code section 501(c)(7).

Revenue Ruling 68-581: Sale by a section 501(c)(3) exempt vocational school of articles made by its students is a related trade or business within the meaning of Code section 513, but selling articles made by non-students is unrelated trade or business.

Revenue Ruling 68-564: A mutual company, whose members are the owners of river front property, formed to contract with the federal government to prevent erosion of river banks may qualify for exemption as a like organization under Code section 501(c)(12).

Revenue Ruling 68-563: A nonprofit religious broadcasting station that does not sell commercial or advertising time is exempt under Code section 501(c)(3) even though it operates on a commercial license.

Revenue Ruling 68-550: Income an exempt organization derives from operating a mailing service for other organizations is income from unrelated trade or business within the meaning of Code section 513, even though the mailing equipment is also used for exempt activities.

Revenue Ruling 68-536: An exempt organization is entitled to only one $1,000 deduction under Code section 512(b)(12) in computing its unrelated business taxable income, regardless of the number of unrelated businesses in which it is engaged.

Revenue Ruling 68-535: A social club that regularly sells liquor to its members for consumption off its premises is not exempt under Code section 501(c)(7).

Revenue Ruling 68-534: An organization publishing a labor newspaper may qualify for exemption under Code section 501(c)(5).

Revenue Ruling 68-505: An exempt section 501(c)(3) county fair association that conducts a horse racing meet with pari-mutuel betting is engaged in an unrelated trade or business within the meaning of Code section 513.

Revenue Ruling 68-504: A nonprofit organization formed and operated to conduct an educational program for bank employees in an area qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 68-490: An exempt section 501(c)(2) title-holding corporation is subject to the unrelated business tax under Code section 511 if one of its parent organizations is subject to the tax.

Revenue Ruling 68-489: An organization will not jeopardize its exemption under Code section 501(c)(3), even though it distributes funds to nonexempt organizations, provided it retains control and discretion over use of the funds for section 501(c)(3) purposes.

Revenue Ruling 68-455: A war veterans' organization qualifies for exemption under Code section if its primary activity is promoting social welfare, even though it operates a resort concession and uses funds to pay for certain buildings; Revenue Ruling 58-517 superseded.

Revenue Ruling 68-438: A nonprofit organization formed and operated to lessen racial and religious prejudice in housing and public accommodations by disseminating the results of its investigations and research may be exempt under Code section 501(c)(3).

Revenue Ruling 68-422: An organization created pursuant to the will of a stockholder of a company to pay pensions to retired employees of that company does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 68-376: Situations in which persons who purchase pharmaceutical supplies from an exempt hospital are considered patients of the hospital for purposes of determining whether the hospital is engaged in unrelated business.

Revenue Ruling 68-375: Selling pharmaceutical supplies by an exempt hospital to private patients of physicians with offices in a hospital-owned medical building is unrelated business.

Revenue Ruling 68-374: Circumstances in which an exempt hospital derives unrelated business taxable income from selling pharmaceutical supplies to the general public.

Revenue Ruling 68-373: A nonprofit organization primarily engaged in testing drugs for commercial pharmaceutical companies does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 68-372: A nonprofit organization that procures, cares for, and displays objects of lasting interest or value relating to a sport may be exempt under Code section 501(c)(3).

Revenue Ruling 68-371: A title-holding corporation exempt under Code section 501(c)(2) will not qualify for exemption after one of the organizations to which it distributes income ceases to qualify for exemption under section 501(a).

Revenue Ruling 68-307: A nonprofit organization formed to help the National Park Service improve its educational and scientific programs may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-306: A nonprofit organization that publishes a newspaper primarily devoted to church and religious matters may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 68-296: Amounts transferred without consideration by a taxable corporation to its sole stockholder, a section 501(c)(3) exempt organization, are distributions constituting dividends to the extent provided in section 316(a) and are not deductible as charitable contributions under section 170.

Revenue Ruling 68-267: An association of retail food merchants exempt from federal income tax under Code section 501(c)(6) that regularly carries on as a minor portion of its activities a coupon redemption service for members is engaged in an unrelated trade or business under Code section 513.

Revenue Ruling 68-266: A nonprofit social club composed of persons who are members of a political party and persons interested in party affairs may be exempt from federal income tax under Code section 501(c)(7), even though it occasionally invites political candidates to address its members.

Revenue Ruling 68-265: A nonprofit organization that operates a credit information service as its primary activity is not exempt from federal income tax under Code section 501(c)(6).

Revenue Ruling 68-264: A nonprofit organization is not exempt from federal income tax under Code section 501(c)(6) if it operates a traffic bureau for members and nonmembers as its primary activity.

Revenue Ruling 68-225: A section 501(c)(3) organization's performance of consulting services for local businesses relating to securing housing for minority group employees is not an unrelated trade or business within the meaning of Code section 513.

Revenue Ruling 68-224: A nonprofit organization that conducts an annual festival centered around regional customs and traditions may qualify for exemption from federal income tax under Code section 501(c)(4).

Revenue Ruling 68-222: That stock is owned by members rather than a fraternity exempt under Code section 501(c)(7) will not disqualify a title holding corporation from exemption from federal income tax under section 501(c)(2), if the stockholders can in no case receive any dividends or profits, all the income from the property, less expenses, being paid over to the organization.

Revenue Ruling 68-182: The Internal Revenue Service will not in similar cases follow the decision in Pepsi-Cola Bottlers' Association, Inc. v. United States, 369 F.2d 259 (7th Cir. 1966). It is the position of the Service that organizations promoting a single brand or product within a line of business do not qualify for exemption from federal income tax under Code section 501(c)(6).

Revenue Ruling 68-175: A religious school operating as a center for adults and combining a personal, group, and subject approach to learning has a regular faculty and a regular enrollment of students in attendance at the place where its educational activities are carried on. Therefore, it is an educational organization within the meaning of Code section 170(b)(1)(A)(ii).

Revenue Ruling 68-168: A nonprofit organization that leases building lots to its members on a long-term basis is not exempt from federal income tax under Code section 501(c)(7).

Revenue Ruling 68-167: A nonprofit organization formed to market the cooking and needlework of needy women may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-165: A domestic nonprofit corporation (composed of educational, civic, business, and other groups) that joins with a counterpart in a Latin American country to promote a student and cultural exchange and provide technical and material assistance for self-help projects to improve the living conditions of underprivileged people in Latin America may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-164: A nonprofit organization formed to promote safety in small boat construction and operation may be exempt from federal income tax under Code section 501(c)(3) as an educational organization.

Revenue Ruling 68-119: A social club does not under certain circumstances jeopardize its exemption from federal income tax under section 501(c)(7) by charging the public admission to its annual steeplechase.

Revenue Ruling 68-118: A nonprofit organization that stimulates the interest of youth in the community in organized sports may qualify for exemption from federal income tax under Code section 501(c)(4).

Revenue Ruling 68-117: A nonprofit organization formed and operated to help needy families in developing countries may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-75: A government agency may be a member of an electric cooperative for purposes of Code section 501(c)(12).

Revenue Ruling 68-74: The activities of a taxable subsidiary of a social club (otherwise exempt from federal income tax under Code section 501(c)(7)) are considered activities of the parent club in determining whether the parent is engaging in business with the general public for profit.

Revenue Ruling 68-73: A nonprofit organization created to minister to the non-medical needs of patients in a proprietary hospital may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-72: A nonprofit organization that operates a supervised facility to bring together young people of college age with church leaders, educators, and leading businessmen of the community for discussions on religion, current events, and social problems and providing personal counseling to young adults on their social and vocational problems may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-71: A nonprofit organization that helps people plan their careers and achieve occupational adjustment by distributing educational publications at a nominal charge and providing free vocational counseling services may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 68-70: A nonprofit organization that seeks to eliminate discrimination in employment may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-59: An exempt organization must exclude the specific deduction of $1,000 provided in Code section 512(b)(12), in computing its net operating loss under section 172.

Revenue Ruling 68-46: A veterans' organization does not qualify for exemption under Code section 501(c)(4) if it primarily engages in renting a commercial building and operating a public banquet and meeting hall having bar and dining facilities.

Revenue Ruling 68-45: A veterans' post that primarily engages in social welfare activities may qualify for exemption from federal income tax under Code section 501(c)(4) even though it receives a substantial portion of its funds from bingo games open to the general public.

Revenue Ruling 68-18: If an organization of the type described in Code section 501(c)(12) uses the accrual method of accounting for federal income tax purposes, compliance with the 85 percent requirement imposed by that section must be determined pursuant to that method.

Revenue Ruling 68-16: A fund set up as an adjunct to an exempt school of business administration, for the sole purpose of providing business students with instruction and experience in managing securities, may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-15: A nonprofit organization that investigates causes of community tension, discrimination, physical deterioration, and juvenile delinquency, disseminates its findings, and attempts to educate the public on how to correct such conditions may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 68-14: A nonprofit organization organized and operated to preserve and develop the beauty of a city may be exempt from federal income tax under Internal Revenue Code section 501(c)(3).

 


 

1967

 

Revenue Ruling 67-447: A school for the study of ballet which offers a formal college preparatory program at the high school level and has a regular curriculum, a regular faculty, and a regular enrollment of students in attendance at the place where its educational activities are carried on, is an educational organization within the meaning of Code section 170(b)(1)(A)(ii).

Revenue Ruling 67-428: A federation of clubs does not qualify for exemption from federal income tax under Code section 501(c)(7).

Revenue Ruling 67-397: Payments to section 501(c)(3) exempt hospitals from federal, state, and local governments, for the care of patients, are not funds contributed by the United States or any State within the meaning of Code section 6033, for the purpose of determining whether the hospital is required to file Form 990.

Revenue Ruling 67-394: An organization of licensed small loan companies may qualify for exemption under Code section 501(c)(6), if formed and operated as described.

Revenue Ruling 67-393: An organization formed to make recommendations about rates, tariffs, rules, regulations, and practices for its members who are regulated by the Interstate Commerce Commission and to publish the prevailing rates may be exempt under Code section 501(c)(6).

Revenue Ruling 67-392: A nonprofit organization that promotes the advancement of young musical artists by conducting weekly workshops, sponsoring public concerts by the artists, and securing paid engagements for the artists to improve their professional standing may be exempt under Code section 501(c)(3).

Revenue Ruling 67-391: A nonprofit organization formed to develop and distribute a community land-use plan may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-390: Requirement for new applications for exemption in case of a change in the structure of organizations exempt under Code section 501(a).

Revenue Ruling 67-381: An organization described in Code section 501(c)(3) will not lose its exempt status where it accepts and pays premiums on an insurance policy in which the assignor retains the right to select the method of payment of the proceeds of the policy due upon his death.

Revenue Ruling 67-368: An organization whose primary activity is rating candidates for public office is not exempt from federal income tax under Code section 501(c)(4) because such activity is not the promotion of social welfare.

Revenue Ruling 67-367: A nonprofit organization whose sole activity is operating a scholarship plan for making payments to pre-selected, specifically named individuals does not qualify for exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-344: An organization of packaging manufacturers which includes in its industry advertising references to brand name products merchandised in its packaging material may be exempt from federal income tax under Code section 501(c)(6).

Revenue Ruling 67-343: The wives of members of a business league, exempt under Code section 501(c)(6), who form an organization to help advance their husbands' profession have a common business interest for purposes of section 501(c)(6); thus, the organization may qualify for exemption under that section.

Revenue Ruling 67-342: A nonprofit organization formed and operated to educate the public on the need for international cooperation in order to create and maintain a peaceful world and which disseminates its educational material by means of commercial television may qualify for exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-327: A nonprofit organization whose only activity is arranging group tours for students and faculty of a university to allow them to travel abroad is not entitled to exemption from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-325: An organization that provides recreational facilities without charge to residents of a township is not organized and operated exclusively for charitable purposes where the basis for charitable qualification is dedication of the facilities involved to community use and the use of the facilities is restricted to less than the entire community based on race.

Revenue Ruling 67-302: A social club that agreed its lessor would manage and operate its facilities may qualify for exemption under Code section 501(c)(7), where the club retains control over the selection of its membership and the amount of initiation fees and dues, and has an option to purchase the property leased by the club and terminate the agreement.

Revenue Ruling 67-296: Income from the conduct of classes by a professional association exempt from tax under Code section 501(c)(6), to qualify persons for a specific status within the particular profession, is not from unrelated trade or business subject to the tax imposed by section 511.

Revenue Ruling 67-295: An organization of businessmen may qualify for exemption from federal income tax under Code section 501(c)(6) where its activities are limited to holding luncheon meetings devoted to discussing, reviewing, and considering problems in a particular industry directed to the improvement of business conditions as a whole.

Revenue Ruling 67-294: A nonprofit organization created to make loans to business entities as an inducement to locate in an economically depressed area in order to alleviate unemployment may be exempt from federal income tax under Code section 501(c)(4).

Revenue Ruling 67-293: An organization substantially engaged in promoting legislation to protect or otherwise benefit animals is not exempt under Code section 501(c)(3), even though the legislation it advocates may be beneficial to the community and most of the attempts to influence legislation may be indirect.

Revenue Ruling 67-292: An organization formed to develop a sanctuary for wild birds and animals for the education of the public may be exempt as an educational organization under Code section 501(c)(3).

Revenue Ruling 67-291: A nonprofit organization that subsidizes a training table for coaches and members of a university's athletic teams furthers the educational program of the university and may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-290: A public hospital corporation, organized under a statute giving it the power to acquire by the right of eminent domain property essential to its purposes, may qualify for exemption under Code section 501(c)(3); the power of eminent domain is not a regulatory or enforcement power of the type referred to in Revenue Ruling 60-384.

Revenue Ruling 67-265: An association that furnishes light and water to members on a cooperative basis may qualify for exemption as a like organization under Code section 501(c)(12), if 85 percent or more of its income consists of amounts collected from members for the sole purpose of meeting losses and expenses.

Revenue Ruling 67-264: An association of nonprofit consumer cooperatives that promotes the cooperative method of doing business may qualify for exemption from federal income tax under Code section 501(c)(6).

Revenue Ruling 67-252: A nonprofit organization whose members are processors, packers, and distributors of agricultural products may be exempt under Code section 501(c)(6) rather than section 501(c)(5).

Revenue Ruling 67-251: A business league that extends financial aid and welfare services to members does not qualify for exemption under Code section 501(c)(6), because part of its net earnings inures to the benefit of private individuals.

Revenue Ruling 67-250: A nonprofit organization that educates the public on the need and desirability for making housing available on a nondiscriminatory basis and encourages investment in such housing may be exempt under Code section 501(c)(3).

Revenue Ruling 67-246: Guidelines on deductibility under Code section 170 of payments made in connection with certain fundraising activities.

Revenue Ruling 67-219: Circumstances under which income from conducting an industry trade show by a section 501(c)(6) exempt organization will not be subject to the unrelated business income tax imposed by Code section 511. Revenue Ruling 58-224 distinguished.

Revenue Ruling 67-218: Income derived from a lease of a pipeline system, consisting of right-of-way interests in land, equipment, and other appurtenant properties, is rent from real property (including personal property leased with the real property) within the meaning of Code section 512(b)(3).

Revenue Ruling 67-217: A nonprofit organization may be exempt under Code section 501(c)(3) where it is formed to provide housing and food service exclusively for students and faculty of a university under the university's rules and regulations and offers the university an option to acquire the property at any time upon payment of an amount equal to the outstanding indebtedness.

Revenue Ruling 67-216: A nonprofit organization formed and operated exclusively to instruct the public on agricultural matters by conducting annual public fairs and exhibitions of livestock, poultry, and farm products may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 67-182: An organization whose only activity is providing a reference library of electric logs, maps, and information services used solely by its members in their oil exploration businesses is not exempt as an organization described in Code section 501(c)(6).

Revenue Ruling 67-176: An organization formed to provide specific services to members of a given profession and to those preparing to enter the profession on matters relating to their practices does not qualify for exemption under Code section 501(c)(6).

Revenue Ruling 67-175: Subsidizing a lawsuit for an injunction to prevent air pollution of a region did not cause an organization of growers and processors of agricultural products to lose its exemption from federal income tax under Code section 501(c)(6).

Revenue Ruling 67-151: An organization formed and operated to prevent children from working in hazardous trades and occupations in violation of state laws may be exempt as organized and operated exclusively to prevent cruelty to children within the meaning of Code section 501(c)(3).

Revenue Ruling 67-150: A nonprofit organization that helps rehabilitate ex-convicts and parolees in order to make them self-supporting and useful citizens may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-149: An organization formed to provide financial assistance to section 501(c)(3) organizations but conducting no operations other than to receive contributions, invest income, and make distributions to such organizations, is exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-148: A nonprofit organized formed to study, research, and reenact Civil War battles may be exempt under Code section 501(c)(3).

Revenue Ruling 67-139: Gem and mineral clubs and a federation of such clubs may qualify for exemption under Code section 501(c)(3) or 501(c)(7) depending upon their forms of organization and methods of operation.

Revenue Ruling 67-138: A nonprofit organization created to provide instruction and guidance to low-income families needing adequate housing and interested in building their own homes may be exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-109: A nonprofit corporation organized and operated to establish and maintain a roller skating rink as a recreational facility for residents of a county, in collaboration with the county government, in a county-owned building it occupies rent free, may qualify for exemption under Code section 501(c)(4) where the rink is open to the general public upon payment of nominal dues and admissions charges as needed to defray operating expenses.

Revenue Ruling 67-104: Where a section 501(c)(2) title holding corporation retains part of its income to apply to indebtedness on property to which it holds title, such retention may be treated as if the parent received the income and used it to make a contribution to the capital of the corporation which applied such contribution to the indebtedness.

Revenue Ruling 67-80: In determining the gross amount of premiums written or received on insurance contracts during a taxable year, for purposes of Code section 501(c)(15), premiums are taken into account without deduction for amounts paid or incurred for reinsurance or for return premiums.

Revenue Ruling 67-77: An organization of dealers in a make of automobile in an area, organized and operated primarily to finance general advertising campaigns to promote the sale of that make of automobile, is performing particular services for its members and is not entitled to exemption as a business league under Code section 501(c)(6).

Revenue Ruling 67-73: A trust fund maintained by a bank to invest and reinvest funds contributed by the bank as trustee of certain section 501(c)(3) charitable trusts, qualifies as a common trust fund under Code section 584, if the fund is otherwise operated in conformity with rules of the Comptroller of the Currency relating to the collective investment of trust funds by national banks.

Revenue Ruling 67-72: An organization created by representatives of labor and management to select individuals for apprentice training, arrange their training, and provide books and supplies used in the training, is exempt from federal income tax under Code section 501(c)(3).

Revenue Ruling 67-71: A nonprofit organization created to improve a public educational system is not exempt under Code section 501(c)(3) where it campaigns on behalf of candidates for election to the school board.

Revenue Ruling 67-9: An organization denied exemption because it engaged in a prohibited transaction described in section 503(c)(1) may not reestablish exemption until the loan which was the prohibited transaction has been repaid or adequately secured.

Revenue Ruling 67-8: A nonprofit membership corporation formed to bring the members of a family into closer association through social and historical activities is exempt under Code section 501(c)(7).

Revenue Ruling 67-7: An organization established by a labor union to provide strike and lockout benefits to members may be exempt as a labor organization under Code section 501(c)(5).

Revenue Ruling 67-6: An association whose activities are primarily devoted to preserving the traditions, architecture, and appearance of a community by individual and group action before the local legislature and administrative agencies on zoning, traffic, and parking regulations may be exempt under Code section 501(c)(4), but is not exempt under section 501(c)(3).

Revenue Ruling 67-5: A foundation controlled by its creator's family and operated to enable the creator and his family to engage in financial activities beneficial to them, but detrimental to the foundation, operates for a substantial non-exempt purpose and serves the private interests of the creator and his family and is not entitled to exemption from federal income tax under section 501(c)(3) of the Internal Revenue Code.

 


 

1966

 

Revenue Ruling 66-360: When a national sorority is created and controlled by a business corporation engaged in furnishing services and supplies to the sorority and its member chapters, neither the sorority nor its chapters can qualify for exemption under Code section 501(c)(7) or 501(c)(4).

Revenue Ruling 66-359: A nonprofit organization may qualify for exemption under Code section 501(c)(3) where it is organized and operated to promote humane treatment of laboratory animals by carrying on a program for the accreditation of animal care facilities that supply, keep, and care for animals used by medical and scientific researchers.

Revenue Ruling 66-358: Acceptance of a contribution of park land by an exempt organization will not affect its exempt status under Code section 501(c)(3) even though the donor retained the right to continue using the picture of a certain scenic view in the park as its brand symbol.

Revenue Ruling 66-354: An organization organized and operated under a collective bargaining agreement, to receive federal and state employment taxes that manufacturer members are required to deduct from the wages of employees of a union, and pay those taxes over to taxing authorities, does not qualify for exemption as an organization described in Code section 501(c)(4), 501(c)(5), 501(c)(6), 501(c)(9), or any other of the subsections of section 501(c) because it does not serve any of the exempt purposes described therein.

Revenue Ruling 66-338: An organization formed to promote the interests of a particular retail trade that advises its members in the operation of their individual businesses and sells supplies and equipment to them is not exempt under Code section 501(c)(6).

Revenue Ruling 66-323: A blood bank organized and operated exclusively for scientific and charitable purposes, to provide a community with permanent facilities for collecting and storing human blood and blood products, and to provide for the public distribution thereof, may be exempt under Code section 501(c)(3).

Revenue Ruling 66-296: A nonprofit organization may qualify for exemption under Code section 501(c)(3) if it obtains funds for charitable grants and contributions by acquiring, with borrowed money, oil and gas production payments.

Revenue Ruling 66-295: The acquisition with borrowed funds of oil and gas production payments from properties in which there is no ownership of working interests will not preclude exemption of an organization that otherwise meets the requirements for exemption under Code section 501(c)(2).

Revenue Ruling 66-273: A nonprofit organization may qualify for exemption under Code section 501(c)(4) where it provides a community with facilities for rifle, pistol, and shotgun practice and instructions in the safe handling and proper care of weapons.

Revenue Ruling 66-260: An organization qualifies for exemption under Code section 501(c)(6) where it is created to investigate and prosecute criminal, fraudulent, and unethical conduct on the part of lawyers, doctors, and laymen in the matter of casualty claims against insurance companies.

Revenue Ruling 66-259: A trust that provides for the reversion of principal on termination to the creator does not qualify for exemption under Code section 501(c)(3).

Revenue Ruling 66-258: A nonprofit organization created to elevate the standards of ethics and morality in the conduct of political campaigns by publicizing its code of fair campaign practices through newspapers, radio, and television, and by furnishing aids to political science and civics teachers for use in school classes, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 66-257: A nonprofit organization formed and operated to help elderly unemployed persons of limited means obtain employment by providing them free counseling and placement services and by educating the general public in the employment capabilities of the elderly qualifies for exemption under Code section 501(c)(3). Revenue Ruling 57-297 distinguished.

Revenue Ruling 66-256: A nonprofit organization formed to conduct public forums at which lectures and debates on social, political, and international matters are presented qualifies for exemption under Code section 501(c)(3), even though some of its programs include controversial speakers or subjects.

Revenue Ruling 66-255: A nonprofit organization that through meetings, films, forums, and publications educates the public in a particular method of painless childbirth is entitled to exemption under Code section 501(c)(3).

Revenue Ruling 66-245: The special limitation provided in Code section 170(b)(1)(A) does not apply to contributions made to a medical research organization that operates in conjunction with a hospital operated for profit.

Revenue Ruling 66-225: A nonprofit organization that provides entertainment for its members does not qualify for exemption under Code section 501(c)(7) where it is controlled by a taxable corporation and operated as an integral part of that corporation's business.

Revenue Ruling 66-223: The operation of a bid registry which is open to all individuals or firms in a particular trade or industry and which has been established and operated as a means of encouraging fair bidding practices within the industry is an appropriate activity for an association that otherwise meets the requirements for exemption under Code section 501(c)(6).

Revenue Ruling 66-222: The operation of an annual rabies clinic by an association of veterinarians will not preclude exemption under Code section 501(c)(6) where the members donate their services and supplies and reduced fees are charged to the public.

Revenue Ruling 66-220: A nonprofit corporation organized exclusively for educational purposes to operate a noncommercial educational broadcasting station presenting educational, cultural, and public interest programs is exempt under Code section 501(c)(3).

Revenue Ruling 66-219: An organization that otherwise meets the requirements for exemption under Code section 501(c)(3) is not precluded from establishing exempt status merely because its creator (if a trust) is either the sole or controlling trustee or merely because the organization is controlled by one individual.

Revenue Ruling 66-212: An organization exempt under Code section 501(c)(9) may reimburse its members for premiums paid under the Medicare program.

Revenue Ruling 66-180: Neither operating gasoline stations nor selling gasoline and oil to the employer company adversely affects the exemption under Code section 501(c)(4) of a local association of employees, because all the organization's income is used for recreational purposes, and income from sales to the employer of its members is considered a form of employer support of the association.

Revenue Ruling 66-179: Depending on its form of organization and method of operation, an organization commonly referred to as a garden club may qualify for exemption as a charitable or educational organization described in Code section 501(c)(3), a civic organization described in section 501(c)(4), a horticultural organization described in section 501(c)(5), or a social club described in Code section 501(c)(7).

Revenue Ruling 66-178: A nonprofit organization created to foster and develop the arts by sponsoring a public art exhibition at which works of unknown but promising artists are selected by a panel of qualified judges for viewing and are gratuitously displayed is exempt under Code section 501(c)(3).

Revenue Ruling 66-151: Managing health and welfare plans for a fee by a business league exempt under Code section 501(c)(6) is an unrelated business within the meaning of Code section 513.

Revenue Ruling 66-150: An organization that holds title to a building housing its parent, which is exempt under Code section 501(c)(4), maintains the building, and operates social facilities in the building, does not qualify for exemption under Code section 501(c)(2) or 501(c)(4), but does qualify under Code section 501(c)(7).

Revenue Ruling 66-149: A social club is not exempt under Code section 501(c)(7) if it regularly derives a substantial part of its income from nonmember sources, such as investment income; a club's right to exemption is not affected, however, if for a relatively short period a substantial part of its income is derived from investing proceeds of the sale of its former clubhouse pending the acquisition of a new home for a club.

Revenue Ruling 66-148: A nonprofit organization formed to establish and maintain a system to store and distribute water, in order to increase underground water levels in a community, is exempt under Code section 501(c)(4).

Revenue Ruling 66-147: An organization qualifies for exemption under Code section 501(c)(3) if it is formed to survey scientific and medical literature published throughout the world and to prepare and distribute free of charge abstracts of such literature.

Revenue Ruling 66-146: An organization organized and operated to further, encourage, and recognize outstanding achievements and contributions of citizens of a state toward the progress and betterment of human endeavor is exempt under Code section 501(c)(3).

Revenue Ruling 66-107: A mortgage or other similar lien on real property acquired by a charitable organization in a liquidating distribution from a corporation is business lease indebtedness within the meaning of Code section 514(c).

Revenue Ruling 66-106: Amounts distributed by a real estate investment trust (within the meaning of Code section 856) to a exempt employees' pension trust are not unrelated business taxable income where the distributions were made out of the earnings and profits of the real estate investment trust and hence were dividends (and, therefore, not unrelated business taxable income under section 512(b)(1)).

Revenue Ruling 66-105: An organization of agricultural producers whose principal activity is marketing livestock for its members does not qualify for exemption under Code section 501(c)(5).

Revenue Ruling 66-104: A nonprofit organization that makes funds available to authors and editors for preparing teaching materials and writing textbooks, and, under the terms of the contract with the publisher, receives royalties from sales of the materials and then shares them with those individuals, does not qualify for as a charitable, educational, or literary organization under Code section 501(c)(3).

Revenue Ruling 66-103: A nonprofit organization providing awards and grants, including scholarships and fellowship grants, to needy individuals to enable them to continue their work in the creative arts, as well as to continue their education and studies, with no monetary benefit to the donor organization, is entitled to exemption under Code section 501(c)(3).

Revenue Ruling 66-102: The term expenses as used in Code section 501(c)(2) includes a reasonable allowance for depreciation determined in accordance with section 167.

Revenue Ruling 66-100: Rules that may be relied on in determining whether a contribution by an individual will be as a gift to a publicly supported organization for purposes of Code section 170.

Revenue Ruling 66-59: An organization of employees whose purpose is to pay lump sum retirement benefits to eligible members or death benefits to their survivors does not qualify for exemption as a local association of employees under Code section 501(c)(4).

Revenue Ruling 66-47: A section 501(c)(3) organization is engaged in an unrelated trade or business as defined in Code section 513 when it regularly sells call options on securities held in its investment portfolio, and is subject to the unrelated business income tax under section 511.

Revenue Ruling 66-46: A nonprofit organization formed to promote public appreciation of group harmony singing and to educate its members and the general public in this type of music is exempt under Code section 501(c)(3) of the Internal Revenue Code.

 


 

1965

 

Revenue Ruling 65-299: A nonprofit organization formed to counsel and assist individuals in solving financial difficulties, by budgeting their income and expenses and effecting an orderly program to pay their obligations, is exempt as a social welfare organization under Code section 501(c)(4).

Revenue Ruling 65-298: A nonprofit organization, organized and operated exclusively to research diseases and other disorders of the human body and to develop scientific methods to diagnose, prevent, and treat them and to demonstrate the results of such research to other physicians and the public through seminars, qualifies as an organization described in Code section 501(c)(3).

Revenue Ruling 65-271: A nonprofit organization created to develop and promote an appreciation of jazz music as an American art form through the presentation of public jazz festivals or concerns is exempt as an educational and charitable organization under Code section 501(c)(3).

Revenue Ruling 65-270: A nonprofit organization that operates and maintains a school to teach the art of dancing, particularly contemporary dancing, qualifies for exemption as an educational organization under Code section 501(c)(3).

Revenue Ruling 65-269: Where an exempt hospital,  to obtain funds to build a new hospital , charges doctor staff members fees as a prerequisite to the use of the hospital facilities, its exempt status is not jeopardized if the fee payments are reasonable in amount and the fee practice is nondiscriminatory.

Revenue Ruling 65-244: An organization that operates a trading stamp plan, under which patrons of its members are given trading stamps redeemable for merchandise at local stores, is not entitled to exemption under Code section 501(c)(6).

Revenue Ruling 65-219: distinguished Revenue Ruling 67-302: A club operated under an agreement that gives its resident agent extensive rights to controls the club's operations for his own benefit is not exempt under Code section 501(c)(7).

Revenue Ruling 65-201: A nonprofit cooperative that sells electrical materials, equipment, and supplies, and furnishes equipment manufacturing, repairing, testing, and other services to members is not a like organization within the meaning of Code section 501(c)(12) and therefore does not qualify for exemption under that section even though its membership is limited to section 501(c)(12) exempt organizations; and a cooperative housing organization operated for the personal benefit of its tenant-owners is not a like organization and does not qualify for exemption.

Revenue Ruling 65-195: A junior chamber of commerce operated exclusively for the promotion of social welfare is exempt under Code section 501(c)(4).

Revenue Ruling 65-191: A nonprofit corporation that maintains a hospital or community center, which provides an environment for social contact between American citizens and foreign visitors and students, is exempt as a charitable and educational organization under Code section 501(c)(3).

Revenue Ruling 65-174: Amounts received by an electric cooperative from a commercial power company that provides electricity to the cooperative's customers using the cooperative's facilities, under circumstances described, are income included in determining if the cooperative meets the 85 percent member income test of Code section 501(c)(12).

Revenue Ruling 65-164: A corporation whose membership is made up of individuals, partnerships, firms, and corporations engaged in an industry qualifies for exemption under Code section 501(c)(6) where it helps members conduct bargaining with employees.

Revenue Ruling 65-99: In determining if an organization exempt under Code section 501(c)(12) meets that section's requirement that 85 percent of its income be from members, the amount of gain the organization must include in its income for the year is the income portion of the installment payment actually received during that period.

Revenue Ruling 65-64: Distributing cash to members of a club formed to provide hunting and fishing facilities for its members by propagating and stocking fish and game on club property does not adversely affect its exemption under Code section 501(c)(7) where such distribution represents an amount received from the state highway department in payment of land condemned for road building purposes.

Revenue Ruling 65-63: A nonprofit organization that, in conducting sports car events for the pleasure and recreation of its members, permits the general public to attend for a fee on a recurring basis and solicits patronage by advertising, does not qualify for exemption as a club organized and operated exclusively for pleasure, recreation and other nonprofitable purposes under Code section 501(c)(7).

Revenue Ruling 65-61: An organization engaged in testing for public safety in and establishing safety standards for the field of pleasure boating is exempt from as one testing for public safety as described in Code section 501(c)(3).

Revenue Ruling 65-60: An organization formed to develop and disseminate a body of new knowledge relating to the social sciences qualifies for exemption as an educational and scientific organization under Code section 501(c)(3).

Revenue Ruling 65-14: An organization formed to promote the tourist industry in its area and whose principal activity is publishing a yearbook consisting largely of paid advertisements for its member is not entitled to exemption as an organization described in Code section 501(c)(6).

Revenue Ruling 65-6: An organization does not qualify for exemption under either section 501(c)(3) or 501(c)(13), where it owns, operates, and maintains a cemetery in which only members of a family, their descendants, and persons intermarried with descendants are entitled to be buried.

Revenue Ruling 65-2: Exemption under Code section 501(c)(3) may be granted to an organization which is organized and operated to teach a particular sport to children by holding clinics conducted by qualified instructors in schools, playgrounds, and parks, and by providing free instruction, equipment, and facilities.

Revenue Ruling 65-1: An organization that promotes the development and design of machinery in connection with a commercial operation, and in connection therewith has the power to sell, assign, and grant licenses with respect to its copyrights, trademarks, trade names, or patent rights, does not qualify for exemption under section 501(c)(3) of the Internal Revenue Code.

 


 

1964

 

Revenue Ruling 64-315: An association of merchants is not exempt under Code section 501(c)(6) where its members are the businesses within a shopping center and it expends its funds and engages exclusively in advertising member merchants in newspapers and on television and radio in order to attract customers to the shopping center.

Revenue Ruling 64-313: A memorial association organized to (1) study and develop methods of achieving simplicity and dignity in funeral and memorial services, (2) educate and inform members and the public about the results of this study, and (3) maintain a registry for ht wishes of members in regards to arrangements following death, is exempt as a social welfare organization under Code section 501(c)(4).

Revenue Ruling 64-275: An organization formed to improve the caliber of candidates representing the United States in international competitions by training athletes, is exempt as an educational organization under Code section 501(c)(3).

Revenue Ruling 64-274: A nonprofit corporation that provides worthy and needy students with free housing and funds to purchase books and instructional supplies and equipment on a gift or interest-free loan is exempt as an organization described in Code section 501(c)(3).

Revenue Ruling 64-231: An entrance fee required to obtain services and residence in a home for the aged, must be included with the required lump sum life-care payment to the home in determining whether the home renders services to all or a reasonable proportion of its residents at substantially less than its cost, to the extent of its financial ability, for purposes of qualifying as an exempt charitable organization under Code section 501(c)(3).

Revenue Ruling 64-217: A perpetual care fund, the income of which is turned over to a profit-making cemetery company for use in maintaining the cemetery properties and burial lots, is not exempt under Code section 501(c)(13).

Revenue Ruling 64-195: The exempt status of a nonprofit educational organization under Code section 501(c)(3) is not affected by its nonpartisan study, research, and assembly of materials in connection with court reform and the dissemination of these materials to the public.

Revenue Ruling 64-194: A fraternal beneficiary society operating under the lodge system qualifies for exemption under Code section 501(c)(8) even though it has a class of social members who are not eligible for benefits.

Revenue Ruling 64-193: A life insurance company that operates under a state permit allowing it to do business in counties within 75 miles of its home office, an area including three large metropolitan trade centers, is not of a purely local character and the organization cannot qualify for exemption as a local life insurance company under Code section 501(c)(12).

Revenue Ruling 64-192: A nonprofit organization organized to educate the public on the quality of radio and television programs through opinion polls, teaching evaluation guides, newsletters, and study kits to better their understanding and judgment of radio and television programs and thereby encourage stations to fulfill their obligations to serve the public interest, may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 64-187: A nonprofit corporation organized to further the purposes of the Area Redevelopment Act, by providing funds through loans to purchase or develop land and facilities to alleviate unemployment in areas classified as redevelopment areas under the Act, is exempt from federal income tax under Code section 501(c)(4) as a civic league.

Revenue Ruling 64-182: An organization meets the primary purpose test of Treas. Reg. § 1.501(c)(3)-1(e)(1), for exemption under Code section 501(c)(3), where it uses charitable contributions and grants to conduct a charitable grant-making program commensurate in scope with its financial resources.

Revenue Ruling 64-175: A nonprofit corporation organized and operated exclusively to stimulate, promote, and develop public interest in the dramatic arts and which operates a permanent repertory theater is exempt under Code section 501(c)(3) as an educational organization, if it meets the other requirements of the statute.

Revenue Ruling 64-128: An organization formed to associate scholars to conduct lectures and hold conferences is organized and operated for educational purposes and exempt under Code section 501(c)(3), but is not a school.

Revenue Ruling 64-118: An organization is not exempt under Code section 501(c)(3) as an educational organization where its primary activity is renting a chapter house to a fraternity composed of students.

Revenue Ruling 64-109: A section 501(c)(13) exempt cemetery company loses its exempt status by establishing and operating a mortuary.

Revenue Ruling 64-108: An organization whose primary activity is operating a parking stamp plan, whereby patrons of its members are afforded automobile parking privileges while shopping at members' stores, is not exempt under section 501(c)(6) of the Internal Revenue Code.

 


 

1963

 

Revenue Ruling 63-247: An organization, even though exempt from federal income tax, which is required to file with the Service a return, statement, or document with respect to itself or another person, must obtain a taxpayer identification number.

Revenue Ruling 63-235: A corporation organized as an adjunct to a university law school to publish a law review journal for the purpose of training students in legal research, writing, and editing, under the control of law school faculty, is exempt as an organization described in Code section 501(c)(3).

Revenue Ruling 63-220: A corporation that extends loans to needy students to enable them to compete their educational programs, at interest rates and on terms more favorable than available commercially, may qualify for exemption under Code section 501(c)(3) as one organized and operated exclusively for charitable and educational purposes. Amplifies Revenue Ruling 61-87.

Revenue Ruling 63-190: A nonprofit organization (not operated under the lodge system), which maintains a social club for members and provides sick and death benefits for members and their beneficiaries, does not qualify for exemption as a social club (section 501(c)(7) of the Internal Revenue Code)), a civic league (section 501(c)(4), or a fraternal beneficiary society (section 501(c)(8)).

 


 

1962

 

Revenue Ruling 62-191: A labor organization, otherwise exempt under Code section 501(c)(5), is subject to the unrelated business income tax imposed by section 511 with respect to income derived from the performance of accounting and tax services for certain of its members.

Revenue Ruling 62-167: A nonprofit organization formed to provide television reception for the community as a whole by retransmitting television signals in an area not adaptable to ordinary reception is entitled to exemption under Code section 501(c)(4).

Revenue Ruling 62-78: Organizations exempt under Code section 501(c)(3) may make distributions of income or other unrestricted funds to a state or municipality, or to an activity which is an integral part thereof, without jeopardizing their exempt status, provided such distributions further the exempt purposes of the donor organizations.

Revenue Ruling 62-71: An organization which, as its primary objective, advocates the adoption of a doctrine or theory which can become effective only by the enactment of legislation is not entitled to exemption under Code section 501(c)(3), because it is an action organization and thus is not operated exclusively for educational purposes within the meaning of that section.

Revenue Ruling 62-66: A committee created by executive order of the governor of a state as an official agency thereof to commemorate United Nations Day and to conduct a continuing program through the state university and public school system to educate the public about the purposes and activities of the United Nations, is not entitled to exemption under Code section 501(c)(3); as an official agency of the state, however, the committee is not required to file federal income tax returns and contributions to it are deductible under section 170(c)(1).

Revenue Ruling 62-17: Payment by a labor organization, otherwise described in Code section 501(c)(5), of death, sick, accident, and similar benefits to members with funds contributed by members, if made under a plan that has as its object the betterment of the conditions of the organization's members, does not preclude the organization's exemption under Code section 501(c)(5).

Revenue Ruling 62-10: The filing of an information return on Form 990, under Internal Revenue Code section 6033, by an organization exempt from tax under section 501(a) does not start the running of the statute of limitations on assessment of the unrelated business income tax imposed by section 511 and required to be reported on Form 990-T.

Revenue Ruling 62-6: Describing requirements that nonprofit organizations established to train, educate, and rehabilitate mentally handicapped children must meet in order to be exempt from certain excise taxes.

 


 

1961

 

Revenue Ruling 61-177: A corporation organized and operated primarily to promote a common business interest and better business conditions of one or more lines of business, which otherwise qualifies for exemption under Code section 501(c)(6), is exempt as a business league even though its sole activity is influencing legislation germane to the common business interest. Modifying Revenue Ruling 54-442.

Revenue Ruling 61-170: An association of professional private duty nurses and practical nurses which supports and operates a nurses' registry primarily to afford greater employment opportunities for its members is not exempt under Code section 501(c)(a) as an organization described in section 501(c)(3).

Revenue Ruling 61-158: An organization created exclusively to promote social welfare, which conducts weekly drawings among members as its principal activity and uses the profits primarily to pay its general expenses is not exempt under Code section 501(c)(4).

Revenue Ruling 61-153: A nonprofit corporation qualifies for exemption under Code section 501(c)(4) where it was established for the sole purpose of cooperating with the parent-teacher association of a school district, by reviewing proposals of and designating the insurance company allowed to solicit accident insurance from the students.

Revenue Ruling 61-137: A cemetery organization is not entitled to exemption under Code section 501(c)(13) where it purchased land for cemetery property for an undeterminable total purchase price which was to be paid for on the basis of a percentage of the gross proceeds realized from the sale of individual lots. Amplified in Revenue Ruling 77-70.

Revenue Ruling 61-87: A corporation formed primarily to make unsecured loans to students at low rates of interest for completing their educational programs is exempt as an organization described in Internal Revenue Code section 501(c)(3), if it is shown to be organized and operated exclusively for charitable and educational purposes.

Revenue Ruling 61-72: Requirements that must be met by a home for the aged, to be exempt under Code section 501(c)(3) (distinguishing Revenue Ruling 57-467).

 


 

1960

 

Revenue Ruling 60-384: A wholly-owned state or municipal instrumentality which is a separate entity and which is organized and operated exclusively for purposes described in section 501(c)(3) of the Internal Revenue Code may qualify for exemption from federal income tax under section 501(a) as an organization described in section 501(c)(3).

Revenue Ruling 60-364: A state agency may file a group return, Form 990, covering all the exempt state-chartered credit unions under its control and supervision, in lieu of each individual credit union filing a separate return.

Revenue Ruling 60-351: A corporation whose sole activity is publishing and public sale of a magazine is not exempt under Code section 501(c)(3).

Revenue Ruling 60-324: A social club exempt under Code section 501(c)(7) may lose its exemption if it makes its club facilities available to the general public on a regular, recurring basis because it may then no longer be considered to be organized and operated exclusively for its exempt purposes.

Revenue Ruling 60-228: An organization otherwise exempt as an agricultural organization described in Code section 501(c)(5) is subject to tax under section 511 on the unrelated business income resulting from services rendered to insurance companies and performance of property management services, in connection with insurance programs provided to its members and other local farmers.

Revenue Ruling 60-206: An exempt pension trust is taxable on income from leasing personal property to an industrial company.

Revenue Ruling 60-193: An organization created to encourage greater participation in governmental affairs is not exempt as an educational organization under Code section 501(c)(3), but may qualify for exemption under section 501(c)(4) as an organization operated exclusively for the promotion of social welfare.

Revenue Ruling 60-169: Federal credit unions satisfy their annual return filing requirement under Code section 6033 by a group return filed by the Bureau of Federal Credit Unions covering all exempt credit unions under its supervision.

Revenue Ruling 60-143: Social and recreational activities conducted by a university alumni association, incidental to its basic purpose of advancing the university's interests, do not preclude the organization from exemption under Code section 501(c)(3).

Revenue Ruling 60-110: Individual contributions to a university endowment association, in trust for use by the university, are not gifts to the university, and the additional deduction under Code section 170(b)(1)(A) does not apply to such contributions.

Revenue Ruling 60-86: The operation of extensive club facilities by an agricultural organization, exempt under Internal Revenue Code section 501(c)(5), is carrying on an unrelated trade or business as defined in Code section 513 and taxable under section 511.

 


 

1959

 

Revenue Ruling 59-391: An organization composed of individuals, firms, associations, and corporation, each representing a different trade, business, occupation or profession, is not entitled to exemption as a business league under Code section 501(c)(6) because it has no common business interest other than a desire to increase sales of members.

Revenue Ruling 59-330: The holding of semiweekly bingo games by an exempt labor organization is a profit-making enterprise not related to its exempt purposes under Code section 501(c)(5), and therefore is an unrelated trade or business as defined in section 513, the income from which is taxable under section 511.

Revenue Ruling 59-310: A nonprofit corporation organized to establish, maintain, and operate a public swimming pool and other recreation facilities for the residents of a community is exempt as a charitable organization described in Code section 501(c)(3).

Revenue Ruling 59-234: A real estate board whose primary purpose or activities is operating a multiple listing system is rendered particular services for its members is not exempt as an organization described in Code section 501(c)(6).

Revenue Ruling 59-155: The retailers excise tax applies to the sale at retail of items of jewelry, furs, toilet preparations, and luggage, handbags, etc., by an organization which is exempt under Code section 501(c)(3), although such articles are received and sold on a consignment basis.

Revenue Ruling 59-95: Failure or inability to file required information returns or otherwise to comply with the provisions of Code section 6033 and the regulations thereunder, may result in the termination of the exempt status of an organization previously held exempt, on the grounds that the organization has not established that it is observing the conditions required for the continuation of exempt status.

Revenue Ruling 59-6: A committee organized to supervise the enforcement of apprenticeship standards in various skilled crafts is exempt under Internal Revenue Code section 501(c)(5).

 


 

1958

 

Revenue Ruling 58-589: Criteria or tests  for determining if an organization qualifies for exemption as an organization described in Code section 501(c)(7).

Revenue Ruling 58-588: An organization formed by several individuals to operate a health, recreational, and social club but whose predominant activity is selling services for profit to an unlimited number of so-called members, who have no voice in the club's management and whose only rights are to use the club's facilities upon the payment of specifies fees, is not a tax-exempt social club within the meaning of Code section 501(c)(7).

Revenue Ruling 58-566: A corporation will not be considered organized as a holding company within the meaning of Code section 501(c)(2) where it has broad power and business purposes far beyond the scope necessary to a holding company.  Also, where part of its income is used to reduce indebtedness on property which will ultimately revert to private individuals, it will not be considered as being operated for exempt purposes.

Revenue Ruling 58-517: Effect on section 501(c)(4) exemption of a war veterans organization of conducting activities unrelated to exempt purposes. Superseded by Revenue Ruling 68-455.

Revenue Ruling 58-502: An association formed to promote and conserve the best interests and true spirit of a game, which has been held to be exempt under Code section 501(c)(6), is not subject to unrelated business income tax under section 511 on income derived from the operation of championship tournaments, the grant of radio and television broadcasting rights, and the sale of publications relating to the rules of the game.

Revenue Ruling 58-501: Where a social club, qualified for exemption under Code section 501(c)(7), finds it impracticable to continue to conduct its activities and as a result, sells its property and liquidates, the sale is incidental to its exempt purposes and the club is still considered to be operated exclusively for pleasure, recreation, and similar purposes up through the date of the sale and distribution of the liquidated assets to its active members.

Revenue Ruling 58-482: Operation of orchards and farms by employees of a charitable trust, under supervision of the trustees, is a profit-making enterprise not related to the trust's charitable purposes, and an unrelated trade or business under Code section 513, income from which is taxable to the trust. However, farm income derived by the trust from a tenant under a lease, is not unrelated business taxable income because it is rent from real property excluded by section 512.

Revenue Ruling 58-294: An organization organized and operated to promote a particular patented product, which it owns, does not qualify for exemption under Code section 501(c)(6) because it engages in activities ordinarily carried on for profit and furthers the business interests of the dealers in the product, rather than the improvement of business conditions of one or more lines of business.

Revenue Ruling 58-276: Gross receipts from a telethon conducted by a television station to raise funds for a section 501(c)(3) charitable organization, all of which were paid over to the charitable organization, are not income to the television station.

Revenue Ruling 58-224: An organization that operates a trade show as its sole or principal activity primarily for the purpose of rendering particular services to individual persons is not entitled to exemption from federal income tax as a business league under Code section 501(c)(6). Distinguished in Revenue Ruling 67-219.

Revenue Ruling 58-194: A corporation organized to operate a book and supply store and a cafeteria and restaurant on the campus of a state university, primarily for the convenience of its student body and the members of its faculty, no part of the net earnings of which inures to the benefit of any private shareholder or individual, may be considered to be operated exclusively for educational purposes and may qualify for exemption as an organization described in Code section 501(c)(3).

Revenue Ruling 58-190: A cemetery company, operated for profit, is not required to include in gross income that portion of the contract sale price of burial lots or mausoleum crypts, which, by requirement of state law or its own by-laws and/or contracts, it is obligated to irrevocably set aside in trust, solely for perpetual care and maintenance of the cemetery, burial lots, or mausoleum crypts to the extent that such portion is so set aside.

 


 

1957

 

Revenue Ruling 57-493: A corporation organized to build a stadium and lease it to a school district, a political subdivision, which will eventually get title to the stadium, is not exempt under Code section 501(c)(3), but may be exempt under section 501(c)(4).  Contributions to it are deductible by donors to the extent provided by section 170 as contributions for the use of a political subdivision for exclusively public purposes.

Revenue Ruling 57-467: (Superseded by Revenue Ruling 72-124) A home for aged people, which does not accept charity guests and which requires the discharge of guests who fail to make certain required monthly payments, is not organized and operated exclusively for charitable purposes or for any of the other purposes specified in section 501(c)(3) of the Internal Revenue Code of 1954 and is, therefore, not entitled to exemption from Federal income tax under such provision of law.

Revenue Ruling 57-466: An organization incorporated under state laws for the county-wide advancement and improvement of agriculture, which in addition to activities furthering its purposes, purchases supplies and equipment for resale to members, is exempt under Code section 501(c)(5), but subject to tax under section 511 on the unrelated business income resulting from the resale of supplies and equipment.

Revenue Ruling 57-453: An organization that publishes the anthologies of member authors and contracts for programs on the radio and television based on the anthologies, serves as a vehicle for publishing materials of its members by calling attention to their professional work and thereby increases the salability of the writers efforts, is engaged in a business for profit and is not exempt under Code section 501(c)(6).

Revenue Ruling 57-420: A nonprofit organization that provides and maintains a two-way radio system for members on a mutual or cooperative basis qualifies for exemption under Code section 501(c)(12), if 85 percent or more of its income consists of amounts collected from members for the sole purpose of meeting losses and expenses.

Revenue Ruling 57-327: Traveling expenses incurred in performing official duties as an uncompensated officer and member of an organization exempt under Code section 501(c)(4), a veterans organization of the type contemplated by section 170(c)(3), are deductible as charitable contributions.

Revenue Ruling 57-313: Operating a medical illustration department, which furnishes photographic, illustrative, and similar services to medical and educational institutions, and an electroencephalography clinic for several hospitals, by a section 501(c)(3) foundation which is organized and operated to conduct and support medical and scientific research, is an unrelated trade or business as defined in section 512, income from which is subject to the tax imposed by section 511.

Revenue Ruling 57-297: A corporation organized to rehabilitate unemployed persons over a certain age is not exempt under Code section 501(c)(3) where it operates an employment service and provides employment and business opportunities for its members, but may be exempt as a civic organization under section 501(c)(4).

Revenue Ruling 57-52: A corporation organized to promote and conduct home shows, the net earnings of which inure to the benefit of a county recreational board as rent for use of its premises, is not exempt under Internal Revenue Code section 501(c)(3) because it is conducting a business ordinarily carried on for profit.

 


 

1956

 

Revenue Ruling 56-486: Criteria for exemption under Code section 501(c)(3) of an alumni association closely affiliated with a university.

Revenue Ruling 56-475: An organization formed to promote and foster the appreciation and techniques of stock car operation and which conducts stock car racing events sponsored by community organizations under agreements whereby a portion of the profits is received by the organization to pay expenses and prizes to members who participate in the races does not qualify for exemption as an organization described in Code section 501(c)(7).

Revenue Ruling 56-403: A foundation may award scholarships solely to undergraduate members of a designated fraternity consistent with exemption under Code section 501(c)(3) as an educational organization.

Revenue Ruling 56-305: Where an operating organization actually engages in club activities and furnishes a chartered organization a meeting place, the organization may qualify for exemption from federal income tax as a social club under Code section 501(c)(7).

Revenue Ruling 56-304: Organizations established as charitable foundations which are organized and actively operated to carry on purposes in Code section 501(c)(3), and which otherwise meet the requirements for exemption from federal income tax, may make distributions of funds to individuals, provided such distributions are made on a charitable basis to further the organizations' purposes; organizations that make such distributions should maintain records to show the name and address of each recipient of aid, the amount distributed to each, the purpose for which aid was given, the manner in which the recipient was selected, and any relationship between the recipient and (1) members, officers, or trustees of the organization, (2) a grantor or substantial contributor to the organization or a member of the family of either, and (3) a corporation controlled by a grantor or substantial contributor.

Revenue Ruling 56-262: An organization whose activities are educational, religious, or charitable, in the broad sense of those words, and which, as a secondary or incidental activity, also maintains an educational institution in the nature of a school, or a church or association of churches, or a hospital, does not qualify under the classes of organizations set forth under Code section 170(b)(1)(A), and is therefore not eligible to receive enhanced charitable deductions provided for organizations described in that section.

Revenue Ruling 56-245: An organization formed to encourage better and more economical methods of raising fur bearing animals, to provide an orderly system for marketing the pelts of its members, and to create a public demand for their products, and which carries out its purposes by furnishing members educational materials on breeding and raising fur bearing animals and marketing pelts, procuring agreements from auction companies to market members' products, and furnishing them certain beneficial services in connection therewith, and conducting advertising to encourage the use of fur products, is exempt under Code section 501(c)(5).

Revenue Ruling 56-185: Criteria or tests to be met in determining if a hospital qualifies for exemption from federal income tax as an organization described in Code section 501(c)(3) (modified Revenue Ruling 69-545).

Revenue Ruling 56-152: Handling an insurance program for a municipal board of education and receiving brokerage commissions which must be deposited in a special fund for public purposes, does not affect the exempt status of an insurance board under Code section 501(c)(6), and is not an unrelated trade or business within the meaning of section 513.

Revenue Ruling 56-138: A trust organized and operated for the primary purpose of paying pensions to retired employees of an employer is not organized exclusively for charitable purposes within the meaning of Code section 501(c)(3).

Revenue Ruling 56-93: A reorganized railroad company which has issued all its first mortgage bonds and the majority of its shares of common stock to the Reconstruction Finance Corporation in satisfaction of a debt, and has also issued and set aside shares of its stock for subscription through warrants issued to private creditors, is not exempt from federal income taxes.

Revenue Ruling 56-84: An organization, operated primarily to promote, sell, and handle national advertising in its members' publications, is performing particular services for individual members as distinguished from improving business conditions of members as a whole and therefore is not entitled to exemption as a business league under Code section 501(c)(6).

Revenue Ruling 56-65: A local organization that principally furnishes particular information and specialized individual service to its individual members engaged in a particular industry is performing particular services for individual persons and therefore is not exempt under Code section 501(c)(6). Clarified Revenue Rulings 65-164 and 72-211.

Revenue Ruling 56-13: An organization that raises funds for use in travel and other activities to interview and persuade prospective students with outstanding athletic ability to attend a particular university, and which is not an integral part of such institution, is not exempt under Code section 501(c)(3) as an educational institution.

 


 

1955

 

Revenue Ruling 55-716: An organization formed to furnish television antenna service to its members is not exempt under Code section 501(c)(7), nor any other provision of federal tax law.

Revenue Ruling 55-715: An organization formed to regulate the sale at auction of a specified agricultural commodity in a certain area, to protect the interests of producers, warehousemen, and purchasers, qualifies for exemption as a board of trade under Code section 501(c)(6).

Revenue Ruling 55-676: A radio station and cinder block plant operated in a commercial manner by an exempt university are unrelated businesses, but a laundry operated by the university primarily for the benefit of its students, is within the exception of section 513(a)(2).

Revenue Ruling 55-656: A community nursing bureau operated as a community project, which maintains a nonprofit register of qualified nursing personnel, qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 55-610: An organization formed to operate the activities which its principal founder conducted as his personal hobby in prior years, which will reimburse the founder for prior years' expenses, is not exempt under Code section 501(c)(3), because a portion of its earnings will inure to the founder's benefit.

Revenue Ruling 55-587: Circumstances under which an interscholastic athletic association qualifies for exemption under Code section 501(c)(3).

Revenue Ruling 55-516: A nonprofit corporation that operates a semiprofessional baseball club as its principal activity is not entitled to exemption under Code section 501(c)(4).

Revenue Ruling 55-495: modified Revenue Ruling 75-199: An organization that provides for the payment of benefits to members or their dependents, but does not operate under the lodge system or for the exclusive benefit of an organization so operating, is not exempt under Code section 501(c)(8), but is exempt under section 501(c)(4).

Revenue Ruling 55-449: A charitable foundation's construction and sale of 80 houses in18 months, to raise funds to support a church, are an unrelated trade or business; where this activity is the foundation's private activity, it is not exempt under the predecessor of Code section 501(c)(3).

Revenue Ruling 55-444: An organization formed to promote the business of an industry, which furthers its purposes primarily by conducting a general advertising campaign to use the products and services of the industry as a whole, is exempt under Code section 501(c)(6), even though such advertising to a minor extent constitutes the performance of particular services for members.

Revenue Ruling 55-439: An organization that gives aid and advice to low and moderate income individuals about finding and constructing housing qualifies for exemption under Code section 501(c)(4).

Revenue Ruling 55-406: An organization organized and operated to make payments to dependent widows and children of policemen or firemen who die in the line of duties qualifies for exemption as a charitable organization under Code section 501(c)(3).

Revenue Ruling 55-319: Circumstances under which a wholly-owned state instrumentality may qualify for exemption under Code section 501(c)(3).

Revenue Ruling 55-311: An association of employees that operates a bus for the convenience of its members does not qualify as a local association of employees under Code section 501(c)(4), nor any other subsection of section 501(c).

Revenue Ruling 55-268: Contributions to a rehabilitation center to provide a building for use in treating handicapped individuals are contributions to a hospital within the meaning of Code section 170(b)(1)(A)(iii).

Revenue Ruling 55-231: An organization whose primary purpose is to promote the circulation of books of one of its incorporators and who purchases such works and makes them available for public use is not organized and operated exclusively for educational or other purposes described in Code section 501(c)(3).

Revenue Ruling 55-230: An association organized to guard the purity of the breed of Welsh ponies, promote interest in it, and establish, maintain, and publish authoritative records qualifies for exemption as an agricultural organization under Code section 501(c)(5).

 


 

1954

 

Revenue Ruling 54-305: A corporation organized and operated to operate a purchasing agency for  its otherwise unrelated members (exempt charitable organizations), is engaged in business activities that would be unrelated if carried on by any of the organizations served; the organization is not exempt as a charitable organization under the Internal Revenue Code.

Revenue Ruling 54-282: A corporation organized by an organization of farm bureaus and governed by farm bureau boards for the purpose of testing soil for farmers and other members of the community, qualifies for exemption as an agricultural organization under a predecessor to Code section 501(c)(5).

Revenue Ruling 54-134: When before incorporating an organization was formed and operated exclusively for charitable purposes, and incorporation merely changed the form of the organization from that of an unincorporated organization to a corporation, an exemption ruling includes the period during which the organization operated in an unincorporated status.

Revenue Ruling 54-73: Income derived from research by a tax-exempt college, university, hospital, or research organization, is not from an unrelated trade or business; but income derived by any organization to which the unrelated business income tax applies from research for the United States or any of its agencies or for a state or political subdivision is not from an unrelated trade or business. (Note: The principles expressed by this ruling are now largely statutory.)

 

Page Last Reviewed or Updated: 21-Apr-2016