Exempt organizations revenue rulings

 

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Exempt organizations revenue rulings (1979-1954)

Published guidance for exempt organizations

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2010s
2000s
1990s
1980s

2010s

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None available during this period.

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.

2000s

None available during this period.

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.

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

None available during this period.

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.

Revenue Ruling 2003-64PDF: 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 2003-49PDF: Questions and answers regarding the reporting and disclosure requirements for Code section 527. This ruling modifies and supersedes Revenue Ruling 2000-49PDF, 2000-44 I.R.B. 430.

Revenue Ruling 2003-32PDF: 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 2003-28PDF: 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 2003-13PDF: 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 2003-12PDF: 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).

Revenue Ruling 2002-67PDF: 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 2002-55PDF: 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 2002-54PDF: Tax consequences of a section 501(c)(12) exempt electric cooperative distributing and selling propane in tanks to its members.

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

None available during this period.

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and answers about the notice and reporting requirements of section 527 of the Internal Revenue Code (modified and superseded by Revenue Ruling 2003-49PDF).

1990s

None available during this period.

Revenue Ruling 98-15PDF:  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).

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

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

Revenue Ruling 95-8PDF: 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.

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

None available during this period.

None available during this period.

None available during this period.

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

1980s

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

None available during this period.

Revenue Ruling 87-126PDF: 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 87-119PDF: 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 87-73PDF: 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 87-2PDF: 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.

Revenue Ruling 86-98PDF: 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 86-95PDF: 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 86-90PDF: 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. 76-47PDF, sec. 4.08. Thus, the grants will not be taxable expenditures under section 4945.

Revenue Ruling 86-77PDF: 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 86-75PDF: 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 86-53PDF: 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 86-49PDF: 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).

Revenue Ruling 85-199PDF: 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 85-184PDF: 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 85-173PDF: 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 85-162PDF: 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 85-160PDF: 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 85-123PDF: 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 85-115PDF: 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 85-110PDF: 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 85-109PDF: 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 85-2PDF: 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 85-1PDF: 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).

Revenue Ruling 84-169PDF: 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 84-140PDF: 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 84-49PDF: 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).

Revenue Ruling 83-170PDF: 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 55-716PDF).

Revenue Ruling 83-166PDF: 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 83-164PDF: 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 74-147PDF).

Revenue Ruling 83-157PDF: 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 69-545PDF).

Revenue Ruling 83-153PDF: 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 83-140PDF: 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 83-104PDF: 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 83-43PDF: 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 83-19PDF: 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 73-571PDF).

Revenue Ruling 82-223PDF: 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 82-218PDF: 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 82-216PDF: 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 82-148PDF: 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 82-139PDF: 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 82-138PDF: 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 82-137PDF: 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 82-136PDF: 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 82-132PDF: 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).

Revenue Ruling 81-293PDF: 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 81-291PDF: 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 81-284PDF: 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 81-276PDF: 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 81-217PDF: 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 76-47PDF apply.

Revenue Ruling 81-178PDF: 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 81-177PDF: 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 81-175PDF: 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 81-174PDF: 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 81-138PDF: 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 81-127PDF: 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 81-125PDF: 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 81-119PDF: 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 81-117PDF: 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 81-116PDF: 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 81-111PDF: 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 81-109PDF: 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 72-36PDF.

Revenue Ruling 81-108PDF: 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 81-101PDF: 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 81-95PDF: 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 81-94PDF: 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 81-76PDF: 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 81-75PDF: 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 81-69PDF: 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 81-68PDF: 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 81-62PDF: 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 81-61PDF: 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 81-59PDF: 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 81-58PDF: 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 75-199PDF).

Revenue Ruling 81-46PDF: 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 81-43PDF: 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 81-40PDF: 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 81-29PDF: 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 81-19PDF: 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.

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

Revenue Ruling 80-310PDF: 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 80-309PDF: 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 80-302PDF: 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 80-301PDF: 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 80-298PDF: 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 80-297PDF: Illustrating the unrelated business income tax treatment of a school's furnishing its tennis facilities to third parties under various circumstances.

Revenue Ruling 80-296PDF: 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 80-295PDF: 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 80-294PDF: 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 80-287PDF: 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 80-286PDF: 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 80-282PDF: 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 80-279PDF: 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 80-278PDF: 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 80-275PDF: 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 80-259PDF: 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 80-215PDF: 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 80-207PDF: 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 80-206PDF: 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 80-200PDF: 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 80-133PDF: 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 80-132PDF: 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 80-130PDF: 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 80-118PDF: 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 80-114PDF: 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 80-113PDF: 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 80-108PDF: 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 80-107PDF: 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 80-103PDF: 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 80-97PDF: 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 80-86PDF: Whether a section 501(c)(12) electric cooperative jeopardizes its exempt status when it sells excess gas at cost to nonmembers.

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