Читать книгу The Law of Tax-Exempt Organizations, 2021 Cumulative Supplement - Bruce Hopkins R., Bruce R. Hopkins, David Middlebrook - Страница 24

p. 196. Insert as second complete paragraph, before heading:

In recent years, the IRS has occasionally drifted away from these general principles.^497.1 That is, the agency may ignore the fundraising aspects of a particular case and focus instead on the nature of the underlying activity, finding that the activity is not an exempt function. For example, the tax‐exempt status of an organization, formed to raise money for charitable purposes by holding motorcycle rallies and making grants to charities, was revoked on the ground that the activities conducted by this entity are “primarily social in nature.”^497.2 This case should have been resolved by application of the commensurate test.^497.3