CHAPTER FOURTEENBusiness Leagues and Like Organizations


(a) General Principles

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The IRS is attempting to discourage the use of small boards, in the case of public charities, by portraying the practice as an inherent form of private benefit.13.1 The agency has made one attempt to import that proposition into the law concerning tax exemption for business leagues. On that occasion, the IRS ruled that an organization did not qualify as an exempt business league, in part because the organization had a self-perpetuating governing board; in that instance, the IRS lamented the absence of “oversight of an independent board.”13.2 Nonetheless, among the federal tax law criteria for business leagues, there is no requirement of an “independent board” (whatever meaning that term may have in this context).


(c) Performance of Particular Services

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p. 421, carryover paragraph, line 18. Delete period and substitute semicolon; insert the following after footnote number:

an organization the membership of which is confined to franchisees affiliated with a specific business corporation;186.1 and an organization operating a farmers' market.186.2

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