I.R.C. § 502(a) General Rule
An organization operated for the primary purpose of carrying on a trade or business
for profit shall not be exempt from taxation under section 501
the ground that all of its profits are payable to one or more organizations exempt
from taxation under section 501
I.R.C. § 502(b) Special Rule
For purposes of this section, the term “trade or business"
shall not include—
I.R.C. § 502(b)(2)
any trade or business in which substantially all the work in carrying on such trade
or business is performed for the organization without compensation, or
I.R.C. § 502(b)(3)
any trade or business which is the selling of merchandise, substantially all of
which has been received by the organization as gifts or contributions.
(Aug. 16, 1954, ch. 736, 68A Stat. 166; Dec. 30, 1969,
Pub. L. 91-172, title I, 121(b)(7), 83 Stat. 542.)
1969--Pub. L. 91-172 redesignated first sentence of existing provisions as subsec. (a), and substantial
portion of second sentence as subsec. (b)(1), and, in subsec. (b)(1)
as so redesignated, inserted reference to section 512 of this title, and added pars.
(2) and (3).
EFFECTIVE DATE OF 1969 AMENDMENT
Amendment by Pub. L. 91-172 applicable to taxable years beginning after Dec. 31, 1969, see section 121(g) of
Pub. L. 91-172, set out as a note under section 511 of this title.