Abstract
This article will describe the statutory and regulatory framework of section 501(c)(3), examine how the test has been applied, criticize the test, and suggest a test more in keeping with the language and the spirit of section 501(c)(3). The proposed test is this: If the questioned activity directly accomplishes an exempt purpose of the organization, and if all profits from the activity are used in a manner consistent with the organization's exempt purposes, 6 then the organization should be granted exempt status, whether or not the organization's activities are imbued with a "commercial hue."
Recommended Citation
Lawrence Zelenak, Serving Two Masters: Commercial Hues and Tax Exempt Organizations, 8 SEATTLE U. L. REV. 1 (1984).
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