Tuesday, November 8, 2011
A member organization argued that its members conducted volunteer activities and that the organization provided scholarships. The IRS determined that the activities included more than an insubstantial part of the activities consisted of social and professional events that benefitted the members. Even the scholarships were limited to members. Thus, the private benefit to the members was not incidental to the exempt purposes of the organization. PLR 201143020 provides an interesting (although not surprising) analysis of the findings that the organization conducted member activities that were more than an insubstantial part of the organization's activities.
Gerry Beyer's Trusts and Estates Blog provides a description and links to the PLR, so this posting is for those of you who don't already ready his terrific blog.