CHAPTER FOURTEEN

Business Leagues and Like Organizations

§ 14.1 Concept of Business League

*(a) General Principles

(c) Line-of-Business Requirement

*(iii) Other Developments

§ 14.2 Disqualifying Activities

*(a) Line-of-Business Requirements

(b) For-Profit Business Activities

(c) Performance of Particular

*(e) Commerciality (New)

§ 14.1 CONCEPT OF BUSINESS LEAGUE

(a) General Principles

*p. 367, second complete paragraph. Insert as second sentence:

The IRS is likely to deny recognition of exemption as a business league where the entity does not have a membership.15.1

(c) Line-of-Business Requirement

p. 370, n. 46. Insert before existing text:

E.g., Priv. Ltr. Rul. 201038015.

p. 371, n. 55, third line. Delete period and insert (at 624). following closing quotation marks.

p. 371, n. 56. Insert following existing text:

Likewise, the IRS denied exempt status as a business league to an organization formed to promote the business interests of its members, all of whom are franchise owners of stores selling a particular brand of pizza (Priv. Ltr. Rul. 201231013).

(iii) Other Developments

*p. 371. Insert as third complete paragraph, before heading:

A nonprofit organization was formed to promote and facilitate the operation and use of tax-qualified master retirement plans for members of an exempt business league. This entity created and maintains these plans for adoption by lawyers and law firms. This organization failed to qualify as an exempt business league itself, largely because its activities ...

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