IRS discusses the commensurate rule; if an organization meets the test outlined in Rev. Rul. 64-182, "exemption will not be foreclosed."

Date
1986
Type
Website
Source
IRS
Non-LDS
Hearsay
Direct
Reference

"1986 EO CPE Text: Update on Fundraising," Internal Revenue Service, 1986, accessed September 27, 2023

Scribe/Publisher
IRS
People
IRS
Audience
Reading Public
PDF
Transcription

. . .

The commensurate test of Rev. Rul. 64-182 remains the basis by which such fundraisers are tested. If this test is met, exemption will not be foreclosed to an organization notwithstanding that its primary fundraising activity in carrying out its purposes is not inherently charitable or is an unrelated trade or business. However, even if the commensurate test is satisfied, exemption may still be defeated if inurement is found, if the facts clearly show other evidence of a primarily private purpose, if political campaigning or substantial lobbying is carried on (other than as permitted by IRC 501(h), or if the organization is a "feeder" organization described in IRC 502

. . .

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