Rameses School of San Antonio, Texas - Page 12




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          The operational test also reinforces the express dictates of                
          section 501(c)(3) in that an entity is deemed not to operate                
          exclusively for exempt purposes if net earnings are distributed             
          or otherwise inure to the benefit of private individuals or if              
          its activities involve proscribed political involvement.  Sec.              
          1.501(c)(3)-1(c)(2) and (3), Income Tax Regs.  Additionally,                
          although an organization may be engaged only in a single activity           
          directed toward multiple purposes, both exempt and nonexempt,               
          failure to satisfy the operational test will result if any                  
          nonexempt purpose is substantial.  Redlands Surgical Servs. v.              
          Commissioner, supra at 71; Copyright Clearance Ctr., Inc. v.                
          Commissioner, supra at 803-804.                                             
               Exempt purposes, in turn, are those specified in section               
          501(c)(3), such as religious, charitable, scientific, and                   
          educational.  Sec. 1.501(c)(3)-1(d)(1)(i), Income Tax Regs.                 
          Charitable is further defined as follows:                                   
               The term “charitable” is used in section 501(c)(3) in                  
               its generally accepted legal sense and is, therefore,                  
               not to be construed as limited by the separate                         
               enumeration in section 501(c)(3) of other tax-exempt                   
               purposes which may fall within the broad outlines of                   
               “charity” as developed by judicial decisions.  Such                    
               term includes: Relief of the poor and distressed or of                 
               the underprivileged; advancement of religion;                          
               advancement of education or science; erection or                       
               maintenance of public buildings, monuments, or works;                  
               lessening of the burdens of Government; and promotion                  
               of social welfare by organizations designed to                         
               accomplish any of the above purposes, or (i) to lessen                 
               neighborhood tensions; (ii) to eliminate prejudice and                 
               discrimination; (iii) to defend human and civil rights                 
               secured by law; or (iv) to combat community                            






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