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Revenue Ruling 78-248

1978-1 C.B. 154 (1978)

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Revenue Ruling 78-248

Internal Revenue Service
1978-1 C.B. 154 (1978)

Facts

The Internal Revenue Service (IRS) received requests for advice as to what types of voter-education initiatives a tax-exempt organization could engage in without endangering the organization’s tax-exempt status. The IRS considered four hypothetical organizations, each of which had been recognized as an exempt organization under § 501(c)(3) of the Internal Revenue Code (code). Organization A distributed to the public, without editorial commentary, a compilation of the voting records on major issues for every member of Congress. Organization B sent a questionnaire covering a wide range of issues to all candidates for state governor. Organization B selected questions based only on the general electorate’s interest in various topics and then distributed the candidates’ responses to the public in a voting guide. Organization C engaged in activity identical to that of Organization B but selected its questions according to a bias on a particular political issue. Organization D distributed a voter guide to the public during election campaigns that compiled incumbent candidates’ voting records but only with respect to votes implicating land conservation, which was an important issue to Organization D.

Rule of Law

Issue

Holding and Reasoning ()

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Taxation of Nonprofit and Exempt Organizations

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