IRS discusses the commensurate rule; if an organization meets the test outlined in Rev. Rul. 64-182, "exemption will not be foreclosed."
"1986 EO CPE Text: Update on Fundraising," Internal Revenue Service, 1986, accessed September 27, 2023
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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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