B. THE CONCEPT OF CHARITY

The Internal Revenue Code section 501(c)(3) provides that an organization organized and operated for "charitable" purposes may qualify for exemption from federal income tax. The concept of what is charitable has varied, however, with the time, the place and the needs of a particular community. The concept of what is charitable is still evolving today. In this topic we will examine the historical sources of charitability, describe what has been and is charitable under the regulations, state the current Service concepts of charity as derived from revenue rulings and finally look at a variety of theories under which charity law continues to evolve.