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§ 7.1 LEGISLATIVE ACTIVITIES LIMITATION (b) Legislative Activities

Оглавление

p. 196, note 26, seventh line. Delete the period; insert following closing quotation mark:

(at 760, note 9).

p. 196, note 26. Delete text following the first period and insert:

Id.

p. 196, note 26. Insert as second paragraph:

An organization formed to protect the human rights of “defenseless victims” from various forms of mind‐control attacks was denied recognition of exemption as a charitable entity primarily because one of its principal activities was advocation of legislation to prohibit or regulate use of attack weapons on the public (Priv. Ltr. Rul. 201430014).

*p. 196. Insert as fourth complete paragraph:

Another way an organization can be classified as an action organization is where its purposes can be achieved only through enactment of legislation. For example, the IRS held that an organization formed to promote transparency in government through technology failed to qualify for tax exemption as a charitable entity because its primary activity is advocating adoption of a theory or doctrine that can become effective only by a legislative enactment.26.1 Likewise, an organization was denied recognition as an exempt charitable entity on the ground it is an action organization, inasmuch as its primary activity, which is obtaining statehood for a “political unit,” can only be attained by the enactment of legislation.26.2

p. 197, first complete paragraph. Insert as third sentence:

On the basis of the principles illustrated in examples in the tax regulations, a court held that a communication refers to a ballot measure “if it either refers to the measure by name or, without naming it, employs terms widely used in connection with the measure or describes the content or effect of the measure.”30.1

The Law of Tax-Exempt Healthcare Organizations

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