Rameses School of San Antonio, Texas - Page 13




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               deterioration and juvenile delinquency. * * * [Sec.                    
               1.501(c)(3)-1(d)(2), Income Tax Regs.]                                 
          Educational is similarly expounded, to wit: “The term                       
          ‘educational’, as used in section 501(c)(3), relates to--(a) The            
          instruction or training of the individual for the purpose of                
          improving or developing his capabilities; or (b) The instruction            
          of the public on subjects useful to the individual and beneficial           
          to the community.”  Sec. 1.501(c)(3)-1(d)(3)(i), Income Tax Regs.           
          Regulations also list several examples of educational                       
          organizations, including “An organization, such as a primary or             
          secondary school, a college, or a professional or trade school,             
          which has a regularly scheduled curriculum, a regular faculty,              
          and a regularly enrolled body of students in attendance at a                
          place where the educational activities are regularly carried on.”           
          Sec. 1.501(c)(3)-1(d)(3)(ii), Example (1), Income Tax Regs.                 
               However, regardless of the presence of what might otherwise            
          be proper exempt purposes, an explicit exception to section                 
          501(c)(3) status exists in that:                                            
               An organization is not organized or operated                           
               exclusively for one or more of the purposes specified                  
               in * * * [section 501(c)(3)] unless it serves a public                 
               rather than a private interest.  Thus, * * * it is                     
               necessary for an organization to establish that it is                  
               not organized or operated for the benefit of private                   
               interests such as designated individuals, the creator                  
               or his family, shareholders of the organization, or                    
               persons controlled, directly or indirectly, by such                    
               private interests.  [Sec. 1.501(c)(3)-1(d)(1)(ii),                     
               Income Tax Regs.]                                                      








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