The Law of Tax-Exempt Organizations, 12th Edition

CHAPTER TWOOverview of Nonprofit Sector and Tax-Exempt Organizations

• § 2.1 Profile of Nonprofit Sector
• § 2.2 Organization of IRS
  • (a) IRS in General
  • (b) Tax Exempt and Government Entities Division
• § 2.3 EO Division's Reports and Work Plans

The nonprofit sector in the United States and the federal tax law with respect to it have a common feature: enormous and incessant growth. As to the sector, this expansion is reflected in all the principal indicators, such as the number of organizations, the sector's asset base, the amount of charitable giving and granting, its annual expenditures, its share of the gross domestic product, and the size of its workforce. There is, however, this direct correlation: As the nonprofit sector expands, so too does the body of federal and state law regulating it. No end to either of these expansions is in sight.¹

Over the years, there have been many efforts to analyze and portray the nonprofit sector. One of the first of these significant undertakings, utilizing statistics, conducted jointly by the Survey Research Center at the University of Michigan and the U.S. Census Bureau, was published in 1975 as part of the findings of the Commission on Private Philanthropy and Public Needs, informally known as the Filer Commission.² The data compiled for the Commission's use were for 1973. Contemporary charitable giving statistics are explored below, but one striking basis of comparison cannot be resisted at this point: Charitable giving in the United States ...