- 15 - providing benefits is passed on to the Schools and hospitals and is the cost that would be incurred if the Schools and hospitals payed the residents themselves. Further, the administrative costs of these activities are not assumed by petitioners because the work is performed by employees of the Schools. Petitioners argue that Rev. Rul. 85-2, 1985-1 C.B. 178, supports their contention that they should qualify as exempt organizations. We disagree. In that revenue ruling, the rules of a local court required the appointment of guardians ad litem to represent children in cases involving abuse. An organization was formed to train volunteer guardians who ultimately replaced court-hired attorneys. The organization was not fully funded by the court. Thus, the organization lessened the burdens of Government. In the present case, petitioners are funded in full by the Schools and hospitals. Petitioners do not contribute any funds toward the education of residents. Consequently, the revenue ruling is not applicable. III. Qualification as “Educational” under Section 501(c)(3) Petitioners' final argument is that they qualify as “educational” organizations. Generally, the term "educational" as used in section 501(c)(3) relates to (1) the instruction or training of an individual for the purpose of improving or developing his capabilities or (2) the instruction of the public on subjects useful to an individual and beneficial to the community. Sec. 1.501(c)(3)-1(d)(3), Income Tax Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011