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Rev. Rul. 77-3, 1977-1 C.B. 140: A nonprofit organization that provides rental housing and related services at cost to a city for its use as free temporary housing for families whose homes have been destroyed by fire is not an exempt charitable organization under Internal Revenue Code section 501(c)(3).
Rev. Rul. 77-4, 1977-1 C.B. 141: A nonprofit organization, whose only activities are preparing and publishing a newspaper of local, national, and international news articles with an ethnic emphasis, soliciting advertising, and selling subscriptions to that newspaper in a manner indistinguishable from ordinary commercial publishing practices, is not operated exclusively or charitable and educational purposes and does not qualify for exemption under section 501(c)(3).
Rev. Rul. 77-5, 1977-1 C.B. 146: A trust, established pursuant to a collective bargaining agreement, that is funded and administered by the employers in an industry to compensate a multi-employer steward who is under the union's direct control with responsibility to settle disputes, investigate complaints, and otherwise encourage compliance with the agreement throughout the whole industry, is a trust qualifying for exemption as a labor organization under section 501(c)(5).
Rev. Rul. 77-6, 1977-1 C.B. 359: The purchase of part of a bond issue on behalf of an section 501(c)(3) exempt hospital by a disqualified person with respect to a private foundation that guaranteed the bonds (other than those sold to the disqualified person) is not an actual of self-dealing.
Rev. Rul. 77-7, 1977-1 C.B. 354: The term "specific project" as defined in section 53.4942(a)-3(b)(2) of the Foundation Excise Tax Regulations includes a project to be undertaken by a public charity unrelated to the private foundation.
Rev. Rul. 77-42, 1977-1 C.B. 142: A nonprofit organization that sets up closed-circuit radio transmitting equipment in multiple residence structures such as nursing homes, rest homes, and convalescent homes, providing senior citizens in the buildings an opportunity to listen to free, non-commercial, and educational broadcasts concerning their special needs, is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).
Rev. Rul. 77-43, 1977-1 C.B. 151: A trust established pursuant to a collective bargaining agreement between an association of employers and a labor union to compensate union members for anticipated lost wages because of the adoption of a new loading process in the shipping industry, with eligibility for benefits not limited to those union members suffering a loss of hours worked or wages, does not qualify for exemption under Code section 501(c)(17).
Rev. Rul. 77-44, 1977-1 C.B. 355: Grants made on an objective and nondiscriminatory basis by a private foundation to worthy college students who acknowledge that they plan to teach in a particular state after graduation satisfy the requirements of section 4945(g) of the Code and are not taxable expenditures under section 4945(d)(3); however, because they are grants to achieve specific objectives as described in section 4945(g)(3) rather than constituting scholarships as described in section 4945(g)(1), the grants are not excludable from recipients' gross income under section 117(a) as scholarships.
Rev. Rul. 77-46, 1977-1 C.B. 147: A nonprofit organization established under a collective bargaining agreement between a union and an employers' association to enable members of the union to save money by having a set amount withheld from their pay and deposited in a bank account, the funds to be paid to them annually with any interest remaining after payment of administration expenses, fails to qualify for tax exemption under Code section 501(c)(5).
Rev. Rul. 77-47, 1977-1 C.B. 157: Buildings acquired through assumption of outstanding mortgages by an exempt organization that restores, preserves, and exhibits buildings of historical and/or architectural significant, constitute debt-financed property within the meaning of Code section 514(b)(1) when they are leased at fair rental; value for uses that neither bear nay relationship to the buildings' historical or architectural significance nor accommodate viewing by the general public.
Rev. Rul. 77-68, 1977-1 C.B. 142: A nonprofit organization formed to provide individual psychological and educational evaluations, as well as tutoring and therapy for children and adolescents with learning disabilities, operates exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).
Rev. Rul. 77-69, 1977-1 C.B. 143: A Health Systems Agency organized and operated pursuant to the National Health Planning and Resources Development Act of 1974 to establish and maintain a system of health planning and resources development aimed at providing adequate health care for a specified geographic area is operated exclusively for charitable purposes and qualifies for exemption under Code section 501(c)(3).
Rev. Rul. 77-70, 1977-1 C.B. 150: A nonprofit cemetery company that acquires land from a for-profit cemetery company, under an agreement providing payment to the former owners based on a percentage of the sales price of each cemetery lot sold, is not exempt form tax as a cemetery described in section 501(c)(13); Rev. Rul. 61-137 amplified.
Rev. Rul. 77-71, 1977-1 C.B. 156: The transfer, subject to an existing mortgage, of an appreciated apartment complex by a tax-exempt section 501(c)(3) hospital to its wholly owned taxable subsidiary in exchange for additional stock in the subsidiary does not result in a gain with respect to which the hospital will be taxed under Code section 511.
Rev. Rul. 77-72, 1977-1 C.B. 157: Indebtedness owed to a labor union by its wholly-owned tax-exempt subsidiary title-holding company resulting from a loan to pay debts incurred to acquire two income-producing office buildings is not acquisition indebtedness within the meaning of Code section 501(c).
Rev. Rul. 77-74, 1977-1 C.B. 352: Amounts accumulated by a private foundation created in 1968 to award scholarships to qualified individuals from a specific high school, as required by the trust instrument, do not reduce the amount required to be distributed under Code section 4942, even though a probate court of competent jurisdiction denied the trustee's request to be excused from compliance with the provision of the trust requiring the accumulation.
Rev. Rul. 77-111, 1977-1 C.B. 144: An organization formed to increase business patronage in a deteriorated area by providing information on the area's shopping opportunities, local transportation, and accommodations, is not operated exclusively for charitable purposes and does not qualify for exemption under Code section 501(c)(3). Similarly, an organization whose purpose is to revive retail sales in an area of economic decline by constructing a shopping center does not qualify for exemption.
Rev. Rul. 77-112, 1977-1 C.B. 149: An organization composed of persons studying for a degree in a particular profession may be an association of persons having a common business interest within the meaning of section 1.501(c)(6)-1 of the Income Tax Regulations.
Rev. Rul. 77-114, 1977-1 C.B. 152: The date of notice for purposes of Code section 508(a) (the requirement to file Form 1023) is the date of the U.S. postmark stamped on the cover in which an exemption application is mailed or, if no postmark appears on the cover, the date the application is stamped as received by the Service.
Rev. Rul. 77-115, 1977-1 C.B. 154: A newly created organization, exempt from tax under Code section 501(c)(3), that wishes to obtain an extended advance ruling for purposes of determining whether it will qualify as a publicly supported organization must submit a request for the extended advance ruling at the same time as its request for an initial advance ruling. Note that the extended advance ruling period procedure is superseded by one five-year advance ruling period in repsonse to Congressional directive contained in the Confernece Committee Report to the Deficit Reduction Act of 1984. See H.R. Rep. No. 98-861, 2d Sess. 1 (1984), 1984-3 C.B. Vol. 2 1090. The regulations have not been updated to reflect this change, however.
Rev. Rul. 77-116, 1977-1 C.B. 155: Support received by an organization before changes made in its operations to enable it to qualify under Code section 501(c)(3) is not taken into account in determining its foundation status under section 509.
Rev. Rul. 77-153, 1977-1 C.B. 147: A nonprofit organization that owns and operates a livestock facility and leases it to local members of a nonexempt national association of farmers for use in implementing the association's collective bargaining program with processors does not qualify for exemption as an agricultural organization under Code section 501(c)(5).
Rev. Rul. 77-154, 1977-1 C.B. 148: A nurses' association whose membership includes a small percentage of self-employed private duty nurses and whose primary activity is acting as a collective bargaining agent for its members qualifies for exemption as a labor organization under Code section 501(c)(5).
Rev. Rul. 77-160, 1977-1 C.B. 351: A private foundation's payment of a disqualified person's church membership dues in order to maintain that person's church membership is an act of self-dealing under Code section 4941(d)(1)(E).
Rev. Rul. 77-161, 1977-1 C.B. 358: A private foundation's loan to a disqualified person that constitutes an act of self-dealing, but otherwise is a permissible expenditure, is not a taxable expenditure within the meaning of Code section 4945(d)(5).
Rev. Rul. 77-206, 1977-1 C.B. 149: Cash rebates made by an exempt business association to member and nonmember exhibitors who participate in the association's annual industry trade show, that represent a portion of an advance floor deposit paid by each exhibitor to insure the show against financial loss, are made to all exhibitors on the same basis, and may not exceed the amount of the deposit, do not adversely affect the association's exempt status under Code section 501(c)(6).
Rev. Rul. 77-207, 1977-1 C.B. 152: A corporation that states it is a private foundation when it files an application for recognition of exemption after the deadline provided by regulation is treated as an organization described in Code section 501(c)(3) and as a private foundation only from the date it files its application.
Rev. Rul. 77-208, 1977-1 C.B. 1 53: A corporation that states it is a publicly supported charity when it files its application after the deadline provided by regulation cannot be treated as an organization described in section 501(c)(3) of the Code before the date it files its application; financial support received prior to that date may not be used for purposes of determining whether the organization is publicly supported.
Rev. Rul. 77-211, 1977-1 C.B. 312: A nonprofit organization operating an improvisational repertory theater and workshops in the study and production of improvisational theater does not qualify as a nonprofit educational organization exempt from tax under Code section 501(c)(3); however, the organization's workshops, which meet the requirements relating to faculty, curriculum, and enrolled study body, qualify as a school operated as an activity of an exempt organization and are exempt from certain excise taxes.
Rev. Rul. 77-212, 1977-1 C.B. 356: Grants by a private foundation to vocational high schools to be used to purchase the basic tools of a trade for students selected by representatives of the foundation are grants to individuals for study and will be taxable expenditures unless the requirements of Code section 4945(g) are met.
Rev. Rul. 77-213, 1977-1 C.B. 357: A private foundation that failed to list on its original annual information return a grant to an organization not described in either section 509(a)(1), (2), or (3) of the Code, but corrected the omission on an amended return filed after the due date, has failed to exercise the expenditure responsibility requirements of section 4945(h)(3) with respect to the grant, and the grant is a taxable expenditure.
Rev. Rul. 77-246, 1977-2 C.B. 190: A nonprofit organization that provides, upon request, low cost bus transportation to senior citizens and handicapped persons in a community where public transportation is unavailable or inadequate qualifies for exemption under Code section 501(c)(3) because it is operated exclusively for charitable purposes.
Rev. Rul. 77-251, 1977-2 C.B. 389: A per diem allowance for travel inside the United States paid to a government official by a private foundation in connection with its educational and charitable purposes is excepted from the tax on self-dealing under Code section 4941(d)(2)(G)(vii) only if the allowance does not exceed 125 percent of the maximum authorized rate of $35 provided by 5 U.S.C. § 5702(a), notwithstanding the provision in section 5702(c) allowing higher rates in designated geographical areas.
Rev. Rul. 77-252, 1977-2 C.B. 390: A private foundation that made an interest-free loan from corpus to a public charity in a year in which its distribution requirements had been met and that continued to meet the distribution requirements during the five-year period without use of the excess of qualifying distributions created by the loan is not required to include in its gross income repayments on the loan and may return the payments to corpus.
Rev. Rul. 77-255, 1977-2 C.B. 75: Contributions by a section 501(c)(6) business league to a section 501(c)(3) organization seeking to be classified as other than a private foundation under section 509(a)(1) because it is publicly supported under section 170(b)(1)(A)(vi) are subject to the two percent limitation imposed by section 1.170A-9(e)(6) of the Income Tax Regulations.
Rev. Rul. 77-258, 1977-2 C.B. 195: A domestic fraternal society operating under the lodge system, which does not provide life, sick, accident, or other benefits, whose members are interested in the use of and philosophy behind a method of attempting to divine the future, and whose net income is used to provide instruction on the use of the method, maintain a reference library, and supply information on the method to the public, qualifies for exemption under Code section 501(c)(10).
Rev. Rul. 77-259, 1977-2 C.B. 387: The purchase by a private foundation of a mortgage from a bank, a disqualified person that in the normal course of its business acquires and sells mortgages, is not within the exception for general banking services and is an act of self-dealing under Code section 4941(d)(1)(A).
Rev. Rul. 77-261, 1977-2 C.B. 45: Income from a fund, established under a written declaration of trust by a state, for the temporary investment of cash balances of the state and its political subdivisions, which purchases units of participation and have an unrestricted right of withdrawal, is excludible from gross income; however, the fund is classified as a corporation and must file a federal income tax return.
Rev. Rul. 77-272, 1977-2 C.B. 191: An organization formed and operated by a labor union at the request of the Bureau of Indian Affairs to provide apprentice training in a skilled trade to American Indians is operated exclusively for charitable and educational purposes and qualifies for exemption under Code section 501(c)(3).
Rev. Rul. 77-273, 1977-2 C.B. 195: A nonprofit organization that provides security services for residents and property owners of a community, who agree to donate money voluntarily at a specified hourly rate to defray the cost of the services, is carrying on a business with the general public in a manner similar to organizations operated for profit and does not qualify for exemption under Code section 501(c)(4).
Rev. Rul. 77-288, 1977-2 C.B. 388: The purchase by a private foundation from a banking institution, a disqualified person with respect to the foundation, of certificates of deposit with a maturity date one year from the date of issue and providing for a reduced rate of interest if they are not held to the maturity date is an act of self-dealing under Code section 4941(d)(1)(B).
Rev. Rul. 77-290, 1977-2 C.B. 26: Circumstances under which amounts received as remuneration by a member of a religious order under a vow of poverty from employment outside the order are includible in the member's gross income for federal income tax purposes and subject to payroll taxes.
Rev. Rul. 77-331, 1977-2 C.B. 388: Guarantee of loans made to disqualified persons under a student loan guarantee program established by a private foundation for the children of its employees is an act of self-dealing under Code section 4941(d)(1)(E).
Rev. Rul. 77-333, 1977-2 C.B. 75: Examples of provisions in the governing instruments of community trusts that meet the requirements of section 1.170A-9(e)(11)(v)(B) of the regulations.
Rev. Rul. 77-334, 1977-2 C.B. 77: Examples of resolutions adopted by community trusts with respect to the administration of such trusts or funds that satisfy the requirements of section 1.170A-9(e)(11)(v)(E) and (F) of the regulations.
Rev. Rul. 77-352, 1977-2 C.B. 35: Bonds issued by a political subdivision to construct an office building to be owned by a tax-exempt hospital that will lease the office space primarily for the individual and private practice of doctors, who are not employees but are affiliated with the hospital, will be industrial development bonds, interest on which is not tax-exempt, even though the leasing is not an unrelated trade or business.
Rev. Rul. 77-365, 1977-2 C.B. 192: An otherwise qualifying nonprofit organization that conducts clinics, workshops, lessons, and seminars at municipal parks and recreational areas, to instruct and educate individuals in a particular sport, is operated exclusively for educational purposes and qualifies for exemption under Code section 501(c)(3).
Rev. Rul. 77-366, 1977-2 C.B. 192: A nonprofit organization that arranges and conducts winter-time ocean cruises during which activities to further religious and educational purposes are provided (in addition to extensive social and recreational activities) is not operated exclusively for exempt purposes and does not qualify for exemption under Code section 501(c)(3).
Rev. Rul. 77-367, 1977-2 C.B. 193: A nonprofit organization formed to create and operate a replica of an early American village is engaging in educational activities similar to those of a museum and qualifies for exemption under Code section 501(c)(3) even though the corporation that donated the land and a substantial percentage of the organization's support benefits by having the village named after it and by having its name associated with the village through both the corporation's and the organization's advertising.
Rev. Rul. 77-379, 1977-2 C.B. 387: A private foundation's transfer of stock in repayment of an interest-free loan, made by a disqualified person and used exclusively for exempt purposes, is tantamount to a sale or exchange of property between the private foundation and the disqualified person and is an act of self dealing under Code section 4941(d)(1)(A).
Rev. Rul. 77-380, 1977-2 C.B. 419: Grants made by a private foundation primarily in recognition of past achievement, with the funds being unrestricted, or earmarked for subsequent travel or study and meeting the requirements of Code section 4945(g), are not taxable expenditures within the meaning of section 4945.
Rev. Rul. 77-381, 1977-2 C.B. 462: A church-affiliated college exempt from tax under Code section 501(c)(3) that trains ministers and lay workers to serve religious functions in the church is an integrated auxiliary of a church within the meaning of section 1.6033-2(g)(5)(i) of the regulations and is not required to file an annual return on Form 990.
Rev. Rul. 77-407, 1977-2 C.B. 77: The requirement of section 1.170A-9(e)(5)(i) of the regulations that an organization must have been in existence for at least one taxable year consisting of at least eight months to obtain a ruling or determination letter that it is not a private foundation by virtue of being described in Code sections 509(a)(1) and 170(b)(1)(A)(vi) does not apply to section 170(b)(1)(A)(iv) organizations.
Rev. Rul. 77-429, 1977-2 C.B. 189: An exempt section 501(c)(2) title-holding corporation may retain part of its income each year to apply to indebtedness on property to which it holds title; the transaction will be treated as if the income had been turned over to the exempt parent which had used the income to make a capital contribution to the title holding corporation which, in turn, applied the contribution to the indebtedness; Rev. Rul. 67-104 superseded in part and obsoleted in part.
Rev. Rul. 77-430, 1977-2 C.B. 194: An otherwise qualifying nonprofit organization that conducts weekend religious retreats, open to individuals of diverse Christian denominations, at a rural lakeshore site at which the participants may enjoy the recreational facilities in their limited amount of free time and that charges no fees qualifies for exemption under Code section 501(c)(3) and operated exclusively for religious purposes.
Rev. Rul. 77-434, 1977-2 C.B. 420: Long-term, low-interest educational loans made by a private foundation under a program that specifically limits the use of the funds to furtherance of the recipient's education at an educational institution described in Code section 170(b)(1)(A)(ii) are individual grants within the meaning of section 4945(g)(3).
Rev. Rul. 77-469, 1977-2 C.B. 196: An organization that filed an application for recognition of exemption under Code section 501(c)(3) in May 1976, after its incorporation in November 1975 to succeed an unincorporated association that had operated for three years without filing an application, will be recognized as exempt from the date of incorporation; an advance ruling concerning the organization's private foundation status may be requested based on support received since incorporation.
Rev. Rul. 77-473, 1977-2 C.B. 421: An elected member of a state legislature who receives a salary of less than $15,000 per year and an expense allowance of a fixed amount for the use of which no accounting need be made to the state, which together amount to more than $15,000 per year, is a disqualified person within the meaning of Code section 4946(a) by virtual of being a government official described in section 4946(c)(5).
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