I know that David Brock is an idiot. He's not a "radical" though.
He's an rdean - not a radical, but a partisan hack.
*shrugs* I won't argue that right now....and be careful, Jillian has a soft spot for Rdean.
anyway, the aca- American Campaign Academy v. Commissioner;
have a gander...
In three recently released determination letters, the IRS denied federal income tax-exemption under section 501(c)(4) to organizations that conducted training programs for members of a particular political party. PLR 201128032 (released July 15, 2011, and dated April 4, 2011), PLR 201128034 (released July 15, 2011, and dated April 18, 2011), PLR 201128035 (released July 15, 2011, and dated April 18, 2011).
For electronic versions of the nine-page exemption rulings:
PLR 201128032, PLR 201128034, and PLR 201128035
Summary
Each ruling involves an organization that conducted a training program for members of a named political party. Each organization applied for recognition of tax-exempt status as a social welfare organization under section 501(c)(4).
The IRS concluded that the organizations training programs primarily benefited the interests of a particular political party and its candidates. Any educational activities undertaken provided a partisan benefit considered to serve private interests rather than the community as a whole. Therefore, the organizations did not operate exclusively for the promotion of social welfare within the meaning of section 501(c)(4) and did not qualify for exemption.
KPMG Observation
In reaching its conclusions, the IRS cited the Tax Courts decision in American Campaign Academy v. Commissionera 1989 case that involved facts similar to those found in the determinations. Although the Tax Court case addressed tax exemption under section 501(c)(3), the IRS stated that the standard for determining what constitutes private benefit applies to both sections 501(c)(3) and 501(c)(4). The fact that the respective organizations were involved in politics had no bearing on the case or the determination letters.
TaxNewsFlash-Exempt Organizations