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Notre Dame Law School

2018

Journal Articles

Nonprofit Organizations Law

Private foundation

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A (Partial) Defense Of Section 501(C)(4)'S “Catchall” Nature, Lloyd Histoshi Mayer Mar 2018

A (Partial) Defense Of Section 501(C)(4)'S “Catchall” Nature, Lloyd Histoshi Mayer

Journal Articles

Internal Revenue Code section 501(c)(4) provides exemption from federal income tax for “social welfare” organizations. The vagueness of this term and the failure of the Treasury Department and Internal Revenue Service to interpret it in a manner that would significantly limit that vagueness has led some commentators to criticize this section’s “catchall” nature. While much scholarly attention has been paid to this criticism with respect to the most visible section 501(c)(4) organizations, particularly those involved in political campaign activity and lobbying, almost no attention has been paid to the many less common types of section 501(c)(4) organizations that illustrate that …