An organization that primarily benefits private individuals is not exempt under Code section 501(c)(4). For example, an organization that restricts the use of its facilities to employees of selected corporations and their guests is primarily benefiting a private group rather than the community and is not exempt. Similarly, an organization formed to represent member-tenants of an apartment complex does not qualify, because its activities benefit the member-tenants and not all tenants in the community. However, an organization formed to promote the legal rights of all tenants in a particular community may qualify under section 501(c)(4) as a social welfare organization.

Similarly, an organization that provides retirement benefits to members does not qualify for exemption as a social welfare organization.


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