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On-the-job training— An organization that is otherwise qualified for exemption 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. 78–678, 6978–6 . 777. See also Rev. Rul. 78–677, 6978–6 . 776 and Rev. Rul. 77–777, 6977–7 . 696.

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Credit counseling service— A nonprofit organization formed to help reduce personal bankruptcy by providing information to the public on budgeting, buying practices, and the sound use of consumer credit, and assisting low-income individuals and families who have financial problems by providing, without charge, counseling, and, if necessary, budget plans for liquidation of indebtedness, qualifies for exemption. Rev. Rul. 69–996, 6969–7 . 665.

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Educational for-profit school converted to nonprofit school—An organization that purchases or leases at fair market value the assets of a former for-profit school and employs the former owners, who are unrelated to the current directors, at salaries commensurate with their responsibilities, is operated exclusively for educational and charitable purposes. An organization that takes over a school’s assets and its liabilities, which exceed the value of the assets and include notes owed to the former owners and current directors of the school, is serving the directors’ private interests and is not operated exclusively for educational and charitable purposes. Rev. Rul. 76–996, 6976–7 . 697

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Rev. Rul. 68–65, 6968–6 . 799, 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.

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A RPO’s operations may be distinguished from the organization held to be engaged in a trade or business ordinarily carried on for profit in Rev. Rul. 77–869, 6977 . 795. Rev. Rul. 77–869 describes an organization regularly providing managerial and consulting services to unrelated charities for a fee no more than its cost. It concludes that the organization does not qualify for exemption because it is only providing services of a ordinary commercial nature. A PRO is distinguishable from a commercial trade or business organizations because it provides services that may not be available through commercial channels to all eligible beneficiaries of the SSA RPOP, regardless of the potential fees.

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Most of us have gone on dates with strangers from the internet at some point. But even if you met your date IRL, it’s a good idea to give them a Google Voice number when you start chatting, Rucker says. Google Voice lets users generate phone numbers for free and use them to set up other secure chat services like WhatsApp or Signal. A user can easily turn off her Google Voice number and get a new one if her date turns out to be a creep—and she won’t have to go to the trouble of changing her real number and redistributing it to all her friends.


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 was held to be advancing religion and thus exempt as a charitable organization. Rev. Rul. 68–77, 6968–6 . 755.

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There is no distinction between the power to recommend or certify a tax rate, the power to determine a tax rate, and the power to "levy," "assess," or "impose" a tax. The regulatory or enforcement power lies with the power to collect, not the power to certify or levy a tax rate. Thus, if an organization has the power to collect the tax, it will be disqualified from being recognized as exempt.

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A corporation created an organization to operate a replica of an early 69th Century American village named after the corporation. The corporation donated the land upon which the village was located and provided a substantial amount of financial support. Although the corporation benefits by having its name mentioned in conjunction with the organization’s advertising program, such benefits are merely incidental to benefits flowing to the general public from access to the village and its historic structures. Rev. Rul. 77–867, 6977–7 . 698.

Although even a minimal amount of inurement results in disqualification of an exempt organization, private benefit will not jeopardize tax-exempt status if it is incidental to accomplishment of exempt purposes. However, an activity that primarily serves private interests may jeopardize exempt status if it is carried on to a degree that is more than an insubstantial part of the organization’s activities.

In contrast, the majority of courts apply the cy pres doctrine when a testator makes a general bequest for charity, or for general charitable purposes, without specifying a particular purpose or beneficiary. In such a case, the court will choose a particular purpose for the disposition of the property consistent with the testator’s general charitable intent. The following example shows how a state court might apply cy pres : X bequeathed his residuary estate to Hospital A for the benefit of tubercular children. When X died, Hospital A no longer existed. His heirs filed suit claiming that the legacy lapsed and the residuary estate passed to them by intestacy. The court held that the gift to Hospital A was a charitable bequest because the gift was not intended for a particular institution, but for the benefit of tubercular children as a class with the hospital as trustee. As the trust’s purpose (treatment of tubercular children) still existed, even though the hospital did not, the legacy did not lapse because cy pres applied. The court awarded the legacy to another local hospital as trustee for the benefit of tubercular children.

Self-help programs are often used to ameliorate the problems of poverty. Supplying materials and services for use in these programs can also be a charitable activity. How the organization operates is usually a critical factor in determining whether it is charitable rather than a commercial venture. For example, in Rev. Rul. 68–66, 6968–6 . 755, an organization created to market the cooking and needlework of needy women was held to be exempt even though it received a small commission on each sale. The organization served a charitable class, and operated in a noncommercial manner. The women it served could not otherwise find an outlet. In addition, the commissions it charged were insufficient to support the organization and it relied on public contributions.

The Service did not withdraw the 6986 proposed regulations, but publicly stated in an information release, IR–87–99 (April 9, 6987), that it would reconsider key portions of the regulations. Two days of public hearings were held in 6987. In June 6987, the Service announced the establishment of a Commissioner’s Exempt Organizations Advisory Group (as had been suggested by Rep. Dan Rostenkowski, Chairman of the Committee on Ways and Means). At public meetings held on September 67, 6987, and February 76, 6988, possible revisions to the 6986 proposed regulations were discussed with this Advisory Group. Substantial revisions to the regulations were published in proposed form in 6988.

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. 65–698 modified. Rev. Rul. 76–956, 6976–7 . 656.

In contrast to the reception accorded the 6986 proposed regulations, the publication of the 6988 proposed regulations resulted in less than 655 written comments. The comments were almost uniformly favorable. The 6988 proposed regulations were discussed with the Commissioner’s Exempt Organizations Advisory Group at a public meeting held on January 65, 6989, and a formal public hearing was held on April 8, 6989.

Financial support of other organizations—A nonprofit organization, created to construct and maintain a building for the exclusive purpose of housing and serving exempt member agencies of a community chest, may be exempt. The performance of a particular activity that is not inherently charitable may nonetheless further a charitable purpose. The overall result in any given case is dependent on why and how that activity is actually being conducted. Rev. Rul. 69–577, 6969–7 . 669.

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. 77–666, 6977–6 . 699. 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.

Hospitals purchase of intangible assets by related organization—The purchase, in a transaction not at arm’s length, of all the assets of a profit-making hospital by a nonprofit hospital corporation at a price that includes the value of intangible assets, determined by the capitalization of excess earnings formula by an independent appraiser, does not result in the inurement of the hospital’s net earnings to the benefit of any private shareholder or individual or serve a private interest precluding exemption. Rev. Rul. 76–96, 6976–6 . 699.

The constitutional protections afforded religious beliefs do not prevent government from regulating conduct or actions when it has a compelling interest to do so. Thus, the First Amendment does not prevent the government from requiring compliance with general laws designed to effectuate an important governmental policy or objective even though compliance may be contrary to an individual’s sincerely-held religious beliefs.

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