In Green v. Connally, 330 F. Supp. 1150 (D.D.C., 1970) aff’d sub nom. Coit v. Green, 404 U.S. 997 (1971), as supplemented and modified by Green v. Miller, 45 AFTR 2d 80–1566, 80–1 USTC 9401 (D.D.C. 1980), the court held that racially discriminatory private schools are not entitled to exemption, and that donations to such schools are non-deductible.

In Prince Edward School Foundation v. Commissioner, 478 F. Supp. 107 (D.D.C. 1979), the court held that a private school did not qualify for exemption because it failed to meet its burden to establish that its policy is to admit black students on the same basis as those of other races. Pertinent facts included:

In Bob Jones University v. U.S. and Goldsboro Christian Schools, Inc. v. U.S., 461 U.S. 574 (1983), the Supreme Court upheld the revocation of exemption under IRC 501(c)(3) of an educational and religious organization that operated a university whose policies forbade interracial dating by its students. The Court concluded that educational institutions practicing racial discrimination based on religious beliefs are not charitable in the common law sense and thus are not entitled to federal income tax exemption.

In Calhoun Academy v. Commissioner of Internal Revenue, 94 T.C. 284 (1990), a court applied the racially nondiscriminatory policy in holding that a school was unable to overcome an inference of discrimination resulting from its creation at the time of desegregation of public schools, its failure to adequately publicize a policy of racial nondiscrimination, and its long history of operation without a single black student being enrolled.

IRC 501(f) provides for the exemption of cooperative service organizations, organized and controlled by schools and organizations operated for the benefit of certain state and municipal colleges and universities, for the collective investment of their funds in stocks and securities.

Under IRC 501(f), an organization shall be treated as an organization organized and operated exclusively for charitable purposes, if:

IRC 501(f) does not apply to any organization formed to promote the furnishing of investment services by private interests even though those services might be made available only to educational organizations. For example, if a private brokerage company or investment advisory company were to initiate the formation of a cooperative investment organization, in order to obtain customers for its business, such an organization would not be exempt under the provisions of IRC 501(f) even though it were limited to schools. (S. Rept. No. 93-888, 2d Session, 1974–2 C.B. 415.)

Publishing printed material may be educational if:

Examples of exempt publishing activities:

Where the dissemination of published material has the characteristics of a trade or business, it is not in furtherance of an exempt purpose. Non-exempt publishing rulings include:

Education of the public may be carried on outside the classroom. The regulations provide examples including: public discussions, forums, panels, lectures, museums, zoos, and planetariums. Reg. 1.501(c)(3)–1(d)(3)(ii). Other examples include:

Organizations that devote most of their effort to research and the development of a new body of knowledge may be educational. The results of the study and research must be available to the public even though it may not be extensively disseminated.

An organization engaged in activities relating to "est" programs involving training, seminars, lectures, etc., in areas of intrapersonal awareness and communication which were conducted under licensing arrangements with a for-profit corporation, was held not to be exempt under IRC 501(c)(3). The court held that although the organization was educational in nature, it served the commercial purposes of the for-profit corporation and, therefore, was not operated exclusively for exempt purposes. est of Hawaii, A Hawaiian Corporation v. Commissioner, 71 T.C. 1067 (1979).

An organization, the primary purpose of which was to train dogs, did not qualify for exemption. Although the dog owners received some instruction as to the training of the dogs, the dogs were the primary objects of the organization’s training classes and evaluation. Since training dogs is not an educational purpose described in IRC 501(c)(3), the organization did not qualify for exemption. Ann Arbor Dog Training Club, Inc. v. Commissioner, 74 T.C. 207 (1980).

An organization composed of consumer counseling agencies qualified for exemption under IRC 501(c)(3). Its principal activities were free information to the general public on budgeting, buying practices, and the sound use of credit; and counseling on budgeting and the use of credit to debt-distressed individuals and families. The agencies were free to charge a nominal fee for the credit counseling. Consumer Credit Counseling Service of Ala., Inc., et al. v. U.S., 44 AFTR 2d 79–5122 (D.D.C. 1978). See also, Credit Counseling Center of Oklahoma, Inc. v. U.S. 45 AFTR 2d 80–1401 (D.D.C. 1979).

An organization which primarily conducted an adoption service was held not to qualify for exemption. The organization’s adoption service was operated in a commercial manner and was more than insubstantial in relation to its charitable and educational activities of providing counseling services to unwed mothers. Indicia of commercial operations included the existence of substantial profits, funds raised exclusively from fixed adoption fees, fixed fees which were prohibitive to a large segment of the community, and medical expenses charged to mothers who decided not to put their babies up for adoption. A further ground for denial was the existence of private benefit to the organization’s sole life member. Easter House v. U.S., 60 AFTR 2d 87–5119 (Ct. Cl. 1987).

Programs for young people may be either educational, as forming the character of youth, or charitable in the broader sense, in that they prevent juvenile delinquency. See Reg. 1.501(c)(3)–1(d)(2). Examples of education of youth are:

An organization, the principal activity of which is the owning and operation of an amateur baseball team that competes in a semi-professional league is exempt. The organization furnishes instructors and coaches for a baseball camp, provides coaches for little league teams, and seeks employment for the members of the baseball team that it owns. The organization’s purpose of promoting, advancing and sponsoring baseball as an amateur sport was not defeated since the team members were amateurs who received no pay and did not share in gate receipts. Hutchinson Baseball Enterprises, Inc. v. Commissioner, 73 T.C. 144 (1980), nonacq. 1980–2 C.B.

Before enactment of IRC 501(k), the Service position was that a nonprofit day care center qualified for exemption under IRC 501(c)(3) only if it was operated in a charitable or educational manner.

IRC 501(k), added to the Code by the Deficit Reduction Act of 1984, provides that organizations providing for the care of children away from their homes are deemed to have "educational purposes" under IRC 501(c)(3), 170(c)(2), 2055(a)(2), and 2522(a)(2) if:

The enactment of IRC 501(k) has no effect on the existing precedents mentioned in paragraph (1) above, and child care organizations covered by those precedents will qualify for exemption under IRC 501(c)(3) without consideration of IRC 501(k).

IRC 501(k) requires that child care be provided for the purpose of "enabling individuals to be gainfully employed." The classes of individuals contemplated by the statute would include any employee or self-employed individual, any enrolled student or vocational trainee, and any individual who is actively seeking employment.

IRC 501(k) requires that "substantially all" of the services of the organization be provided to the children of individuals described in paragraph (4) above. This requirement should be deemed to be satisfied if the parents or guardians of at least 85 percent of the children served fall within the designated classes of individuals. Where the 85 percent test is not met, the case should be referred to the National Office.

IRC 501(k) requires that services be "available to the general public." This statutory requirement would normally be satisfied even though the organization has an enrollment restriction based on political boundaries (e.g., enrollment limited to person residing in a particular county, city, or school district). On the other hand, a restriction that limits enrollment to children of a particular employer would normally violate the requirement that services be "available to the general public." However, in such cases an alternative basis for exemption may be available. For example, if enrollment was limited to children of employees of a governmental agency, it might be shown that the organization is "lessening the burdens of government" within the meaning of Reg. 1.501(c)(3)–1(d)(2); or, if enrollment was limited to children of employees of a private employer, the organization might qualify as a voluntary employees’ beneficiary association under IRC 501(c)(9).

A child care organization that has educational purposes solely by virtue of IRC 501(k) is not a private school subject to the requirements of Rev. Proc. 75–50, 1975–2 C.B. 587. Nevertheless, although a child care organization need not meet the specific requirements of Rev. Proc. 75–50, supra, pursuant to the requirements of the law of charity, as applied to educational organizations (and to child care organizations through IRC 501(k)), such an organization cannot be racially discriminatory. See Bob Jones University v. United States, 461 U.S. 574 (1983). All the facts and circumstances must be evaluated to determine if an IRC 501(k) organization is racially discriminatory. An application for exemption containing indicia of racial discrimination or questionable selective admissions criteria should be referred to the Washington POD. A child care organization seeking and meeting the requirements of IRC 170(b)(1)(A)(ii) is subject to the requirements of Rev. Proc. 75–50, supra.

Determinations under IRC 501(c)(3) for IRC 501(k) child care organizations are subject to the same requirements for exemption and foundation status classification as other IRC 501(c)(3) organizations. In most cases, an IRC 501(k) organization which receives the majority of its funding from fees for child care services, will satisfy the requirements for either an advance or definitive non-private foundation ruling under IRC 509(a)(2).

Public education through the mass media frequently gets into areas that are controversial. While the term educational includes the instruction of the public on subjects useful to the individual and beneficial to the community, what an organization claims to be educational may in fact be political or legislative activities. Generally, exemption under IRC 501(c)(3) is precluded for those organizations which are substantially engaged in attempting to influence legislation or those which participate in or intervene in any political campaign on behalf of any candidate for public office.

Certain activities that touch on the political and/or legislative scenes have been held to be outside the scope of the statutory prohibitions. In one instance, for example, a nonprofit educational organization exempt under IRC 501(c)(3) became interested in the question of court reform at the same time the State legislature was considering amending the State constitution. In that case, however, the organization’s activity was limited to the study, research and assembly of materials and the presentation of an objective analysis to those interested in court reform including those who oppose it as well as those who favor it, and to the general public. Accordingly, it was held that such activity was not an attempt to influence legislation and thus did not affect the organization’s exempt status. (Rev. Rul. 64–195, 1964–2 C.B. 138.) In another instance a nonprofit organization formed to elevate the standards of ethics and morality in the conduct of political campaigns by disseminating information concerning general campaign practices, furnishing teaching aids to political science and civics teachers, and publicizing its proposed code of fair campaign practices without soliciting the signing or endorsement of the code by candidates was held to qualify for exemption as an educational organization. Rev. Rul. 76–456, 1976–2 C.B. 151.

The extent to which partisan political topics may be considered educational has long been a problem. The problem first arose in the context of attempts to influence legislation. Organizations using the mass media to persuade voters to a certain political view and to bring about particular legislation were sometimes held to be noneducational. (See Noah Slee v. Commissioner, 42 F.2d 184 (2nd Cir. 1930).) However in Bertha Poole Weyl v. Commissioner, 48 F.2d 811(2nd Cir. 1931), a distinction was made for the discussion of controversial topics with legislative implications, if the discussion was not primarily directed toward the enactment of particular legislation. Also, in Rev. Rul. 74–574, 1974–2 C.B. 160, a distinction is made where an organization exempt under IRC 501(c)(3) operates a broadcasting station presenting religious, educational, and public interest programs, and provides 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. The organization endorsed no candidate or viewpoint and was held not to be participating in political campaigns on behalf of public candidates in violation of IRC 501(c)(3).

Attempts to influence legislation are now specifically covered by statute. The problem relating to the definition of "educational" is now a comparatively narrow one— how to classify public discussion of controversial topics. Rev. Rul. 68–263, 1968–1 C.B. 256, holds that the publication of material which discredits particular institutions and individuals on the basis of unsupported opinions and incomplete information about their affiliations is not educational. In Rev. Rul. 66–256, 1966–2 C.B. 210, however, an organization that conducted public forums, lectures, and debates on controversial social, political, and international questions was held to be educational. Although the speakers were frequently controversial, the organization adopted an unbiased position. Organizations doing research or educating the public on controversial public issues must stick to the reasoned approach and avoid unsupported opinion. They must also avoid the advocacy of specific legislation as a substantial part of their activity.

A nonprofit organization whose purpose is to educate the public concerning the accuracy and fairness of news coverage by local newspapers was held to be exempt. (See Rev. Rul. 74–615, 1974–2 C.B. 165.) By educational methods, the organization encouraged the newspapers to meet high standards of journalism.

An 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 as an organization described in IRC 501(c)(3). Rev. Rul. 79–26, 1979–1 C.B. 196.

Certain publications of congressional incumbents’ voting records on selected issues in a nonpartisan newsletter do not constitute participation or intervention in any political campaign within the meaning of IRC 501(c)(3). Rev. Rul. 78–248 amplified by Rev. Rul. 80–282, 1980–2 C.B. 178.

The Service has published the criteria used to determine the circumstances under which advocacy of a particular viewpoint or position by an organization is considered educational within the meaning of Reg. 1.501(c)(3)–1(d)(3). This criteria is set forth in Rev. Proc. 86–43, 1986–2 C.B. 729, sec. 3. Two court decisions have considered challenges to the constitutionality of Reg. 1.501(c)(3)–1(d)(3). One decision held that the regulation was unconstitutionally vague. Big Mama Rag v. U.S., 631 F.2d 1030 (D.C. Cir. 1980). However, in National Alliance v. U.S., 710 F.2d 868 (D.C. Cir. 1983), the court upheld the Service’s position that the organization in question was not educational. Although the latter decision did not reach the question of the constitutionality of Reg. 1.501(c)(3)–1(d)(3), it did note that the methodology test used by the Service when applying the regulation "tends toward ensuring that the educational exemption be restricted to material which substantially helps a reader or listener in a learning process." The court also noted that the application of this test reduced the vagueness found in the earlier Big Mama Rag decision. The methodology test cited by the court in National Alliance reflects the longstanding Service position that the method used by an organization in communicating its position, rather than the viewpoint or position itself, is the standard for determining whether an organization has educational purposes. This methodology test is used in all situations where the educational purposes of an organization that advocates a particular viewpoint or position are in question.

Hobby clubs may be exempt if their principal purpose is educational, and the Service has recognized certain garden clubs and mineralogical societies as educational. (See Rev. Rul. 66–179, 1966–1 C.B. 139, and Rev. Rul. 67–139, 1967–1 C.B. 129.)

Generally, hobby clubs exempt under 501(c)(3) are ones that conduct structured educational programs for members and the public, issue newsletters or bulletins containing educational material, maintain reference libraries and prepare displays and exhibits for the public. Recreational and social activities must be insubstantial. The way in which the clubs select their members must be consistent with an educational (as opposed to social or recreational) purpose.

Repertory theater— A nonprofit corporation which is organized exclusively for charitable, scientific, literary, or educational purposes and more specifically to stimulate, promote, and develop the interest of the American public in the dramatic arts, and which operates a permanent repertory theater, is exempt under IRC 501(c)(3). Rev. Rul. 61–175, 1964–1 (Part 1) C.B., 185.

Fraternity chapter house— An organization does not qualify for exemption under IRC 501(c)(3) as an educational organization where its primary activity is to furnish, on a rental basis, a chapter house to a fraternity. However, a corporation, fund, or foundation so organized may, under proper circumstances, be classified as a club organized and operated exclusively for pleasure, recreation and other nonprofitable purposes and exempt under IRC 501(c)(7). Rev. Rul. 64–118, 1964–1 (Part 1) C.B. 182.

Repertory theater— A foundation was formed for charitable, educational, and literary purposes. In furtherance of its purposes, it creates interest in the development of the American theater by aiding local communities to establish their own charitable and educational repertory theaters. It also contributes part of its funds to exempt charitable organizations. No part of its net income inures to the benefit of any private individual. Such a foundation is held to be an exempt organization described in IRC 501(c)(3). Rev. Rul. 64–174, 1964–1 (Part 1) C.B., 183.

Educational; evaluating radio and television programs— A nonprofit organization formed for the purpose of educating the public as to the quality of radio and television programs by means of opinion polls, teaching evaluation guides, newsletters, and study kits to better their understanding and judgment of radio and television programs and thereby encourage broadcasters to fulfill their obligations to better serve the public interest may qualify for exemption under IRC 501(c)(3). Rev. Rul. 64–192, 1964–2 C.B. 136.

Educational; evaluating prospective legislation— The IRC 501(c)(3) status of a nonprofit educational organization is not affected by its nonpartisan study, research, and assembly of materials in connection with prospective legislation relating to court reform and the dissemination of such materials to the public. Rev. Rul. 64–195, 1964–2 C.B. 138.

Student aid corporations— An organization which provides housing, books and educational supplies, as a gift or on an interest-free loan basis, to qualified students who would otherwise have to discontinue their education for lack of funds, is exempt as a charitable organization. Rev. Rul. 64–274, 1964–2 C.B. 141.

Sailboat racing training— An organization formed for the purpose of training suitable candidates in the techniques of racing sailboats in national and international competition, and thereby improving the caliber of candidates representing the United States in Olympic and Pan-American games, qualifies for exemption from Federal income tax as an educational organization described in IRC 501(c)(3). Rev. Rul. 64–275, 1964–2 C.B. 142.

Educational; community sports foundation— A foundation operated exclusively to teach children a sport by holding clinics conducted by qualified instructors in schools, playgrounds, and parks and by providing free instruction, equipment, and facilities qualifies for exemption under IRC 501(c)(3). Rev. Rul. 65–2, 1965–1 C.B. 227.

Educational research in social sciences— An organization formed for the primary purpose of developing and disseminating a body of new knowledge relating to the social sciences, whose activities consist of the performance of scientific research under contracts with governmental agencies, the results being communicated to the public through seminar courses, lectures, and public discussions, and through publications distributed free to depositary libraries qualifies for exemption under IRC 501(c)(3). Rev. Rul. 65–60, 1965–1 C.B. 231.

Foreign students and visitors hospitality center— A nonprofit corporation organized to extend hospitality to foreign visitors and students, promote cultural and educational programs, and provide an environment for social contact between American citizens and foreign visitors and students that accomplishes these purposes by maintaining and operating a community or hospitality center is, under the circumstances, exempt from tax under IRC 501(c)(3). Rev. Rul. 65–191, 1965–2 C.B. 157.

Dancing school— A nonprofit organization formed to operate a school to teach the art of dancing, particularly contemporary dancing, that maintains a regular faculty and curriculum with a regularly enrolled body of students, is exempt from tax under IRC 501(c)(3). Rev. Rul. 65–270, 1965–2 C.B. 160.

Jazz music appreciation— 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 concerts is exempt from tax under IRC 501(c)(3). Rev. Rul. 65–271, 1965–2 C.B. 161.

Medical research and education— A nonprofit organization, organized and operated on a non-membership basis exclusively for the purpose of carrying on research as to diseases and other disorders of the human body and to develop scientific methods for diagnosis, prevention, and treatment thereof, and then to demonstrate the results of such research to other physicians and the public through means of seminars, qualifies for exemption under IRC 501(c)(3). Rev. Rul. 65–298, 1965–2 C.B. 163.

Group harmony singing— 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 may qualify for exemption from Federal income tax under IRC 501(c)(3) as an educational organization. Rev. Rul. 66–46, 1966–1 C.B. 133.

Creative arts awards— A nonprofit organization providing awards and grants, including scholarships and fellowships, to needy individuals to continue their education or their work in the creative arts with no monetary benefit to the donor is exempt from tax. Rev. Rul. 66–103, 1966–1 C.B. 134.

Publishing teaching materials and textbooks— A nonprofit organization which 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 published materials and then shares them with the editors and authors, does not qualify for exemption under IRC 501(c)(3). Rev. Rul. 66–104, 1966–1 C.B. 135.

Evaluating scientific and medical literature— An organization formed to survey medical and scientific articles published throughout the world and to abstract selected articles of note in a monthly publication that is distributed free to interested parties requesting to be put on the mailing list is exempt from tax under IRC 501(c)(3). Rev. Rul. 66–147, 1966–1 C.B. 137.

Art exhibit sponsorship— A nonprofit organization created to foster and develop the arts by sponsoring a public art exhibit at which the works of unknown but promising artists are selected by a panel of qualified judges for viewing and are gratuitously displayed is exempt from tax under IRC 501(c)(3). Rev. Rul 66–178, 1966–1 C.B. 138.

Garden clubs— Illustrations under which garden clubs may establish exemption as charitable or educational organizations, civic organizations, horticultural organizations, or as social clubs. Rev. Rul. 66–179, 1966–1 C.B. 139.

Broadcasting station; noncommercial— A nonprofit corporation organized exclusively for educational purposes to operate a noncommercial educational broadcasting station presenting educational, cultural, and public interest programs is exempt from Federal income tax under IRC 501(c)(3). Rev. Rul. 66–220, 1966–2 C.B. 209.

Painless childbirth— A nonprofit organization which through meetings, films, forums, and publications educates the public in a particular method of painless childbirth, is entitled to exemption from Federal income tax under IRC 501(c)(3). Rev. Rul. 66–255, 1966–2 C.B. 210.

Political education— A nonprofit organization created to elevate the standards of ethics and morality in the conduct of campaigns for election to political office by publishing 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 as an educational organization. Rev. Rul. 60–193 modified. Rev. Rul. 76–456, 1976–2 C.B. 151.

Accreditation of animal care facilities— A nonprofit organization which promotes 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 is advancing education and science and thus exempt as a charitable organization. Rev. Rul. 66–359, 1966–2 C.B. 219.

Apprentice training program— An organization created by representatives of both labor and management to select individuals for apprentice training, arrange their classroom and on-the-job training, and provide books and supplies used in the training is exempt from tax under IRC 501(c)(3). Rev. Rul. 67–72, 1967–1 C.B. 125.

Housing guidance to low-income families— A nonprofit organization created to provide instruction and guidance to low-income families in need of adequate housing and interested in building their own homes is exempt from tax under IRC 501(c)(3). Rev. Rul. 67–138, 1967–1 C.B. 129.

Civil War research— A nonprofit organization formed to increase the knowledge of its members and the public about historic events of the Civil War by researching, studying, and involving its members in historically accurate reenactments of Civil War battles to which the public is invited may be exempt under IRC 501(c)(3). Rev. Rul. 67–148, 1967–1 C.B. 132.

Rehabilitating ex-convicts and parolees— A nonprofit organization which furthers the rehabilitation of ex-convicts and parolees in order to make them self-supporting and useful citizens may be exempt from tax under IRC 501(c)(3). Rev. Rul. 67–150, 1967–1 C.B. 133.

Agricultural; fairs— 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 be exempt from tax under IRC 501(c)(3). Rev. Rul. 67–216, 1967–2 C.B. 180.

University housing and food service— A nonprofit organization may qualify for exemption under IRC 501(c)(3) where it is formed to provide housing and food service exclusively for students and faculty of a university in accordance with the rules and regulations of the university and offers the university an option to acquire the property at any time upon payment of an amount equal to the outstanding indebtedness. Rev. Rul. 67–217, 1967–2 C.B. 181.

Promoting nondiscriminatory housing— An organization formed to educate the public about the need for making housing available to members of the public on a nondiscriminatory basis and to encourage investment in such housing may be exempt from tax under IRC 501(c)(3). Rev. Rul. 67–250, 1967–2 C.B. 182.

Training table for university’s athletic teams— A nonprofit organization which 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 under IRC 501(c)(3). Rev. Rul. 67–291, 1967–2 C.B. 184.

Educational; wild bird and animal sanctuary— An organization formed for the purpose of developing a sanctuary for wild birds and animals for the education of the public may be exempt as an educational organization under IRC 501(c)(3). Rev. Rul. 67–292. 1967–2 C.B. 184.

International cooperation for peace; commercial television— A nonprofit organization which is 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 under IRC 501(c)(3). Rev. Rul. 67–342, 1967–2 C.B. 187.

Community land-use plan— A nonprofit organization formed to develop and distribute a community land-use plan may be exempt from tax under IRC 501(c)(3). Rev. Rul. 67–391, 1967–2 C.B. 190.

Sponsoring young musical artists— A nonprofit organization which encourages and 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 from tax under IRC 501(c)(3). Rev. Rul. 67–392, 1967–2 C.B. 191.

Career planning and occupational adjustment— A nonprofit organization that helps people in planning their careers and in achieving occupational adjustment by distributing educational publications at a nominal charge and providing free vocational counseling qualifies for exemption under IRC 501(c)(3). Rev. Rul. 68–71, 1968–1 C.B. 249.

Coffee house— A nonprofit organization formed by local churches to operate a supervised facility, known as a "coffee house," in which persons of college age are brought together with church leaders, educators, and leading businessmen of the community for discussions and counseling on religion, current events, social and vocational problems, may be exempt as a charitable organization under IRC 501(c)(3) since it is advancing both education and religion. Rev. Rul. 68–72, 1968–1 C.B. 250.

Aiding needy in developing countries— A nonprofit organization formed and operated to assist needy families in "developing" countries by teaching modern farming methods and furnishing other technical assistance is advancing education and thus exempt under IRC 501(c)(3) as a charitable organization. Rev. Rul. 68–117, 1968–1 C.B. 251.

Small boat safety— An organization formed to develop and disseminate standards of safety in small boat design, construction, and operation is instructing the public on subjects useful to the individual and beneficial to the community and may be exempt under IRC 501(c)(3). Rev. Rul. 68–164 1968–1 C.B. 252.

Publication; discrediting institutions and individuals— An organization formed to promote the education of the public on patriotic, political and civic matters, and to inform and alert the public on the dangers of an extreme political doctrine is not exempt under IRC 501(c)(3) because, as a substantial part of its activities, it distributes publications that seek to discredit particular institutions and individuals on the basis of unsupported opinions and incomplete information about their affiliations and activities. Rev. Rul. 68–263, 1968–1 C.B. 256.

National Park Service programs— A nonprofit organization formed to assist the National Park Service, Department of the Interior, in furthering its educational and scientific programs may be exempt from tax under IRC 501(c)(3). Rev. Rul. 68–307, 1968–1 C.B. 258.

Sports museum— A nonprofit organization that procures, cares for, and displays objects of lasting interest or value relating to a particular sport may be exempt under IRC 501(c)(3). Rev. Rul. 68–372, 1968–2 C.B. 205.

Study courses provided— An organization formed to conduct an educational program for bank employees, whose courses are limited to its members and whose membership is open to area bank employees, qualifies for exemption under IRC 501(c)(3). Rev. Rul. 68–504, 1968–2 C.B. 211.

Bus transportation for private school children— A nonprofit organization, formed by parents of pupils attending a private school, that provides school bus transportation for its members’ children serves a private rather than a public interest and does not qualify for exemption under IRC 501(c)(3). Rev. Rul. 69–175, 1969–1 C.B. 149.

College; employment furnished students— An organization wholly owned by a tax-exempt college is not eligible for exemption under IRC 501(c)(3) if it manufactures and sells wood products primarily to employ students of the college to enable them to continue their education. Rev. Rul. 69–177, 1969–1 C.B. 150.

Scholarships— A nonprofit organization awarding scholarships based on scholastic ability, without regard to financial need, may qualify for exemption under IRC 501(c)(3). Rev. Rul. 69–257, 1969–1 C.B. 151; Rev. Rul. 66–103, 1966–1 C.B. 134; Rev. Rul. 56–403, 1956–2 C.B. 307; Rev. Rul. 67–367, 1967–2 C.B. 188; Rev. Rul. 63–220, 1963–2 C.B. 208; and Rev. Rul. 61–87, 1961–1 C.B. 191.

Foreign educational program— A nonprofit organization that selects students and faculty members who are interested in a particular foreign history and culture and enrolls them in foreign universities, transports them to and from that country, and conducts on-site tours qualifies for exemption under IRC 501(c)(3). Rev. Rul. 69–400, 1969–2 C.B. 114. See also, however, Rev. Rul. 67–327, 1967–2 C.B. 187.

College; book and supply store— An organization that operates a college book and supply store serving exclusively members of the faculty and student body of the college and refunds its excess earnings to members in proportion to their purchases qualifies for exemption under IRC 501(c)(3). Rev. Rul. 69–538, 1969–2 C.B. 116.

Fraternity— An organization built a chapter house with proceeds from contributions from students and alumni. The house serves as a social center for members and has living quarters, study rooms and a library. The organization is not exempt under IRC 501(c)(3) but is exempt under IRC 501(c)(7). Since the fraternity is not organized and operated exclusively for IRC 170(c) purposes contributions to it are not deductible. Rev. Rul. 69–573. 1969–2 C.B. 125.

Research in anthropology— 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 was held to be advancing education and science. Rev. Rul. 70–129, 1970–1 C.B. 128.

Campaign materials— An organization formed to collect and collate campaign materials of a candidate for an historically important elective office for donation to a university or public library was held to qualify under IRC 501(c)(3) as an educational and charitable organization. Rev. Rul. 70–321, 1970–1 C.B. 129.

Children’s day care center— An educational day care center operated in conjunction with an industrial company that enrolls children on the basis of family financial need and the child’s need for the care and development program of the center qualifies for exemption. Rev. Rul. 70–533, 1970–2 C.B. 112.

Travel study tours— A nonprofit organization whose primary activity is conducting travel study tours that include courses on the culture of the U.S., foreign countries, and nature studies taught by certified personnel qualifies for exemption under IRC 501(c)(3). Rev. Rul. 70–534, 1970–2 C.B. 113.

College students; internship programs— A nonprofit organization that recruits college students for internship programs providing work experience in various phases of government related to their studies while enabling them to contribute to the community furthers a charitable purpose by advancing education and relieving the burdens of government. Rev. Rul. 70–584, 1970–2 C.B. 114.

Marriage counseling service— A nonprofit organization that provides personal marriage counseling services and conducts workshops and seminars on the subject of marital adjustment qualifies for exemption under IRC 501(c)(3). Rev. Rul. 70–640, 1970–2 C.B. 117.

Honor Society for women— A national honor society for women organized to recognize scholastic achievements and to serve various universities and colleges where chapters are established in furthering education qualifies for exemption. Rev. Rul. 71–97, 1971–1 C.B. 150.

Art gallery— 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 IRC 501(c)(3). Rev. Rul. 71–395, 1971–2 C.B. 228.

Clearinghouse and course coordinator; classes in community— A nonprofit organization acting as a clearinghouse and course coordinator by bringing together instructors and interested students in a community for purposes of instruction on subjects useful to individuals and beneficial to the community is exempt from tax under IRC 501(c)(3). Rev. Rul. 71–413, 1971–2 C.B. 228.

Private school; racially nondiscriminatory policy— A private school that does not have a racially nondiscriminatory policy as to students does not qualify for exemption. Rev. Rul. 71–447, 1971–2 C.B. 230.

International exposition— An organization that conducts an international exposition commemorating certain historical events and cultural achievements and exhibiting products of various nations, qualifies for exemption under IRC 501(c)(3). Rev. Rul. 71–545, 1971–2 C.B. 235.

Community welfare; solid waste pollution— An organization formed to educate the public regarding environmental deterioration due to solid waste pollution and operated with contributions and proceeds from sale of collected solid waste such as old newspapers, glass containers, and metal cans for recycling qualifies for exemption under IRC 501(c)(3). Rev. Rul. 72–560, 1972–2 C.B. 248.

Drama and musical arts appreciation— A nonprofit organization created to develop a community appreciation for drama and musical arts by sponsoring professional presentations such as plays, musicals, and concerts, qualifies for exemption under IRC 501(c)(3). Rev. Rul. 73–45, 1973–1 C.B. 220.

On-the-job training— An organization that is otherwise qualified for exemption under IRC 501(c)(3) will not fail to qualify because its educational and vocational training of unemployed and underemployed persons is carried out through the manufacturing and selling of toy products. Rev. Rul. 73–128, 1973–1 C.B. 222; see also, however, Rev. Rul. 73–127, 1973–1 C.B. 221.

Educational organization; membership based on compatibility— An organization that selects its membership from the junior class of a college primarily on the basis of compatibility without regard to scholarship, and that holds closed meetings at which personally oriented speeches and discussions are carried on by the speaker-members, is not operated for exclusively educational purposes and does not qualify for exemption under IRC 501(c)(3). Rev. Rul. 64–117 superseded. Rev. Rul. 73–439, 1973–2 C.B. 176.

Counseling women on unwanted pregnancies— 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. Rev. Rul. 73–569, 1973–2 C.B. 178.

Credit unions in developing nations— An organization formed to assist individuals in developing nations to improve their living conditions through educational programs on credit problems and to instruct and train individuals from those nations in the techniques of organizing and managing credit unions qualifies for exemption as an educational organization. Rev. Rul. 74–16, 1974–1 C.B. 126.

Computer users— 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 IRC 501(c)(3). Rev. Rul. 74–116, 1974–1 C.B. 127.

Accreditation of educational institutions— A nonprofit organization of accredited educational institutions, whose membership includes a small number of proprietary schools, and whose activities include the preparation of accreditation standards, identification of schools and colleges meeting these standards, and the dissemination of accredited institution lists is exempt as an educational organization. Rev. Rul. 74–146, 1974–1 C.B. 129.

Broadcasting station; free air time to political candidates— An organization exempt under IRC 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. Rev. Rul. 74–574, 1974–2 C.B. 160.

Counseling men on voluntary sterilization methods— 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 IRC 501(c)(3). Rev. Rul. 74–595, 1974–2 C.B. 164.

Regional computer network— 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 IRC 501(c)(3). Rev. Rul. 74–614, 1974–2 C.B. 164. See also, however, Rev. Rul. 74–116, 1974–1 C.B. 127.

Church operated schools with discriminatory policies.— 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 IRC 170 and 501(c)(3). Rev. Rul. 75–231, 1975–1 C.B. 158.

Training program for high school graduates and college students— 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 IRC 501(c)(3). Rev. Rul. 75–284, 1975–2 C.B. 202.

Preservation of buildings having historical or architectural significance— 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 IRC 501(c)(3). Rev. Rul. 75–470, 1975–2 C.B. 207.

Film festival sponsorship— A nonprofit organization formed to promote the art of film making by conducting annual festivals to provide unknown independent film makers with opportunities to display their films and by sponsoring symposiums on film making qualifies for exemption under IRC 501(c)(3). Rev. Rul. 75–471, 1975–2 C.B. 207.

Educational television; program producer— An otherwise qualifying organization that produces and distributes free (or at small cost-defraying fees) educational, cultural, and public interest programs for public viewing via public-educational channels of commercial cable television companies is operated exclusively for educational purposes and is exempt from Federal income taxes under IRC 501(c)(3). Rev. Rul. 76–4, 1976–1 C.B. 145.

Construction trades training center; sale of homes— A nonprofit organization that purchases building lots, furnishes funds to a public vocational training center for 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 IRC 501(c)(3). The income from the sale of the homes is not unrelated business income. Rev. Rul. 76–37, 1976–1 C.B. 148.

Art gallery— 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 IRC 501(c)(3); Rev. Rul. 71–395 clarified. Rev. Rul. 76–152, 1976–1 C.B. 151.

Aid to immigrants— A nonprofit organization formed to aid immigrants in overcoming social, cultural, and economic problems by providing personal counseling, referrals to helpful agencies, social and recreational activities, instruction in English, and distributing a newsletter containing information on attaining citizenship, securing housing, and obtaining medical care is operated exclusively for charitable and educational purposes and qualifies for exemption under IRC 501(c)(3). Rev. Rul. 76–205, 1976–1 C.B. 154.

Promotion of classical music radio programs— A nonprofit organization formed to generate community interest in the retention of 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 the sponsors, soliciting subscriptions to the station’s program guide, and distributing materials promoting the classical music programs, all of which activities tend to increase the station’s revenues, does not qualify for exemption under IRC 501(c)(3). Rev. Rul. 76–206, 1976–1 C.B. 154.

Noncommercial television programs— A nonprofit organization that makes facilities and equipment available to the general public for the production of 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 IRC 501(c)(3). Rev. Rul. 76–443, 1976–2 C.B. 149.

Health care improvements— A nonprofit organization formed to encourage and assist in establishment of nonprofit regional health data systems, to conduct studies and propose improvements with regard to 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 IRC 501(c)(3). Rev. Rul. 76–455, 1976–2 C.B. 150. Rev. Rul. 74–553 distinguished.

Closed-circuit radio broadcasting system— A non-profit 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 within the building an opportunity to listen to free, noncommercial and educational broadcasts concerning their special needs, is operated exclusively for charitable and educational purposes and qualifies for exemption under IRC 501(c)(3). Rev. Rul. 77–42, 1977–1 C.B. 142.

Children and adolescents with learning disabilities— A nonprofit organization formed to provide individual psychological and educational evaluations, as well as tutoring and therapy, for children and adolescents with learning disabilities is operated exclusively for charitable purposes under IRC 501(c)(3). Rev. Rul. 77–68, 1977–1 C.B. 142.

Community sport activity— A 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 IRC 501(c)(3). Rev. Rul. 77–365, 1977–2 C.B. 192.

Counseling widows— A nonprofit organization formed to provide individual and group counseling to widows to assist 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 considered to be operated exclusively for educational purposes and qualifies for exemption under IRC 501(c)(3). Rev. Rul. 78–99, 1978–1 C.B. 152.

Homosexuality— 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 IRC 501(c)(3). Rev. Rul. 78–305, 1978–2 C.B. 172.

Law student’s work in legal aid— A nonprofit organization formed for the purpose of assisting a school’s law students, chosen on the basis of merit and interest, to obtain practical experience with exempt public interest law firms and legal aid societies and that supplements the nominal salaries paid to the students by the participating firms and societies and obtains its funds from contributions of students and alumni is operated exclusively for charitable and educational purposes as described in IRC 501(c)(3). Rev. Rul. 78–310, 1978–2 C.B. 173.

Promoting sports for children— An organization formed to develop, promote, and regulate a sport for individuals under 18 years of age by organizing local and statewide competitions, promulgating rules, organizing officials, presenting seminars, distributing a newsletter, and otherwise encouraging growth of the sport qualified for exemption under IRC 501(c)(3). Rev. Rul. 70–4 distinguished by Rev. Rul. 80–215, 1980–2 C.B. 174.

Publication of voting records— Certain publications of congressional incumbents’ records on selected issues in a nonpartisan newsletter do not constitute participation or intervention in any political campaign within the meaning of IRC 501(c)(3). Rev. Rul. 80–282, 1980–2 C.B. 178. Rev. Rul. 78–248 amplified.

Genealogical research (public interest)— A genealogical society that (1) opens its membership to all persons in a particular area, (2) provides instruction in genealogical research techniques to its members and to the general public, but does not research genealogies for its members, (3) conducts research projects and makes the results available to the state historical society, (4) provides materials for libraries and community displays, and (5) promotes various other related activities for the public qualifies for exemption under IRC 501(c)(3). Rev. Rul. 80–301, 1980–2 C.B. 180. Rev. Rul. 80–302 distinguished.

Genealogical research (private interest)— An organization that (1) limits its membership to descendants of a particular family (2) compiles family genealogical research data for use by its members for reasons other than to conform to the religious precepts of the family’s denomination, (3) presents the data to designated libraries, (4) publishes volumes of family history, and (5) promotes social activities among family members does not qualify for exemption under IRC 501(c)(3). Rev. Rul. 80–302, 1980–2 C.B. 182. Rev. Ruls. 71–580 and 80–301 distinguished.

Training for political campaign workers; limited to one political party— An organization that operates a school to train individuals to fill responsible positions in political campaigns does not qualify for exemption under IRC 501(c)(3) where it fails to establish that it operates on a nonpartisan basis. In American Campaign Academy v. Commissioner, 92 T.C. 1053 (1989), the court concluded that the organization, an outgrowth of similar training programs sponsored by the National Republican Congressional Committee, operated for the private benefit of Republican entities and candidates, who were not members of a charitable class. Although the organization had no formal requirement that candidates for admission be affiliated with any particular political party, the evidence suggested that most of its graduates went on to work in Republican campaigns, and the organization offered no evidence of an graduate who was affiliated with a domestic political party other than the Republican party.

Rev. Rul. 70–585, 1970–2 C.B. 115, describes four different nonprofit housing organizations created to lessen neighborhood tensions, eliminate prejudice and discrimination, and combat community deterioration by providing housing for low or moderate income families. Three of the organizations qualify for exemption under IRC 501(c)(3), one does not. The four situations are:

An organization operated a self-help home building program for low-income families in need of adequate housing was recognized exempt under IRC 501(c)(3) in Rev. Rul. 67–138, 1967–1 C.B. 129. In addition to combating community deterioration, the organization’s activities provided relief to the underprivileged, lessened the burdens of government, and were educational.

An organization provided small, short-term, interest-free loans to low-income homeowners unable to obtain a loan elsewhere to promote the rehabilitation of a badly deteriorated residential area of a city was recognized exempt under IRC 501(c)(3) in Rev. Rul. 76–408, 1976–2 C.B. 145. Although the organization’s activities were conducted in a badly deteriorated residential area of a large city, Rev. Rul. 76–408 emphasized the charitable class aided in finding the organization charitable because it relieves the poor and distressed.

Economic development is a desirable goal sought by virtually every community on some way. However, not all desirable goals are "charitable" within the meaning of IRC 501(c)(3). Determining whether particular economic development activities are charitable requires analyzing the conditions the organization seeks to improve, what the organization seeks to achieve and how it plans to achieve them, who will benefit, and whether benefits to noncharitable interests will be incidental to achieving charitable purposes.

An organization that purchased blighted land in a depressed area, converted it into an industrial park, and leased the land to business tenants who were required to hire and train a significant number of unemployed persons living in the area, was held exempt under IRC 501(c)(3) in Rev. Rul. 76–419, 1976–2 C.B. 146. The organization was funded pursuant to a public law providing for the such programs in areas with urban blight, little industry, and high unemployment and underemployment of low-income persons.

Rev. Rul. 74–587, 1974–2 C.B. 162, describes a nonprofit organization that qualified for exemption under IRC 501(c)(3) by providing low-cost loans to businesses in economically depressed areas. Because of lack of development capital, limited entrepreneurial skills of business owners, social unrest and instability in the area, and depressed economic conditions in the larger region, many businesses in the target areas had declined, fallen into disrepair, or failed. The organization combats these conditions by providing working capital, either through low-interest loans or purchases of equity interests, to businesses that cannot obtain commercial financing. The terms of financing were reasonably related to the needs of the particular businesses, and the organization disposed of any equity interest as soon as the particular business’ success was reasonably assured.

Rev. Rul. 81–284, 1981–2 C.B. 130, amplifies Rev. Rul. 74–587, supra, by describing how the standards for exemption apply to a nonprofit small business investment company licensed under §301 (d) of the Small Business Investment Act to provide low-cost or long-term loans to businesses in economically depressed areas. An organization licensed under §301 (d) cannot aid disadvantaged businesses to the extent described in Rev. Rul. 74–587 because SBA regulations impose lending standards that limit the businesses eligible for loans, and also require a organization to charge an interest rate sufficient to recover the cost of its loan funds. Rev. Rul. 81–284 holds that the SBA requirements do not preclude a §301 (d) licensee from being organized and operated exclusively for charitable purposes, but the mere fact that an organization is licensed under §301 (d) does qualify it for exemption under IRC 501(c)(3).

Exemption was denied to an organization that increased business patronage in an economically deteriorated area as well as to an organization that revived lagging sales in a particular area in Rev. Rul. 77–111, 1977–1 C.B. 144. One organization sought to increase business in a deteriorated area by promoting the area through media advertising and other means. The other organization sought to combat economic decline of an urban area by constructing a shopping mall to make the area more competitive with outlying shopping areas. Although the first organization’s activities may further charitable purposes, they were not limited to members of a charitable class. They overall thrust was to promote business generally. The second organization failed to further primarily charitable purposes because it primarily benefited businesses that located in the shopping center.

Activities to prevent deterioration may benefit a community in a charitable manner regardless whether the community is now or presently in a state of decline, provided the interests served are public in scope and not merely the private interests of a class of persons that do not constitute a charitable class.

An organization that preserved and developed the beauty of a city by planting trees in public areas, assisting municipal authorities in keeping the city clean, and informing the public of the advantages of these programs was held to be organized and operated exclusively for charitable purposes in Rev. Rul. 68–14, 1968–1 C.B. 243.

An organization that worked to improve conditions in an area of a city where the income level was higher and housing better than in other areas of the city by providing information on methods of counteracting housing deterioration and ways of improving homes was held exempt in Rev. Rul. 76–147, 1976–1 C.B. 151. The organization identifies community problems and encourages their resolution through pamphlets and brochures, open meetings, and letter-writing campaigns.

Rev. Rul. 68–15, 1968–1 C.B. 244, held and organization engaged in a variety of activities directed to combating community deterioration and juvenile delinquency, lessening neighborhood tensions, and eliminating prejudice and discrimination. Among its activities that furthered charitable purposes, the organization investigated complaints of possible building code and zoning violations that could result in community deterioration, identified uses for vacant lots to keep them from becoming hangouts, and sponsored meetings and other activities to relieve racial tensions both within the schools and within the larger community.

Rev. Rul. 86–49, 1986–1 C.B. 243, recognizes that preserving he historic or architectural character of a community through acquiring and occasionally restoring historically or architecturally significant properties can serve to prevent community deterioration within the meaning of Reg. 1.501(c)(3)–1(d)(2). The organization set up a revolving fund to acquire and resell these properties subject to restrictive covenants, to preserve the historic or architectural character of the community. The organization’s manner of operations achieved its charitable purposes without serving private interests because:

An organization that developed and distributed a community land use plan was held exempt under IRC 501(c)(3) in Rev. Rul. 67–391, 1967–2 C.B. 190.

An organization that educated the public regarding environmental deterioration due to solid waste pollution and operated recycling centers staffed by volunteers was held exempt under in Rev. Rul. 72–560, 1972–2 C.B. 248. The organization, which was supported by contributions and proceeds from sale of collected solid waste for recycling, engaged in exclusively charitable activities. In addition to educating the public on subjects useful to the community, the organization combated environmental deterioration through the operation of its recycling centers.

Litigation and mediation are permissible means to achieve charitable environmental purposes.

Rev. Rul. 67–151, 1967–1 C.B. 134, held an organization formed to protect children from working at hazardous occupations in violation of state laws and in unfavorable work conditions is an organization for the prevention of cruelty to children.

An organization promoting high standards of care for laboratory animals was held exempt in Rev. Rul. 66–359, 1966–2 C.B. 219. The organization accredited laboratories that gave satisfactory care to experimental animals. This was an exempt purpose, described as charitable, supporting education and science, and preventing cruelty to animals.

Rev. Rul. 74–194, 1974–1 C.B. 129, holds a nonprofit organization formed to prevents the birth and eventual suffering of unwanted animals, by subsidizing spaying or neutering for pet owners who otherwise cannot afford the services, exempt under IRC 501(c)(3).

Organizations formed to prevent cruelty to animals often engage in attempts to influence legislation. This activity is appropriate, unless it is more than an insubstantial part of the organization’s activities, or, if the organization elects under IRC 501(h), it engages in excess lobbying. See, Rev. Rul. 67–293, 1967–2 C.B. 185.

Income derived by an exempt organization from boarding and grooming services is income from an unrelated trade or business under IRC 513. See Rev. Rul. 73–587, 1973–2 C.B. 192.

The Representative Payee Organization Program (RPOP) of the Social Security Administration (SSA) permits qualified organizations to collect disability insurance and supplemental security insurance payments for individuals who are mentally or physically debilitated due to:

The funds are used to ensure the personal care and well-being of SSA beneficiaries.