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Which one of the following types of organizations qualifies as an organization exempt from income tax?

a. An "action" organization established for the purpose of influencing legislation pertaining to protection of animal rights.

b. An organization whose purpose is to foster national or international amateur sports competition by providing athletic facilities and equipment.

c. A social club organized and operated exclusively for the pleasure and recreation of its members, supported solely by membership fees, dues, and assessments.

d. All "feeder" organizations, primarily conducting business for profit, but distributing 100% of their profits to organizations exempt from income tax.

答案：C

Explanation

Choice "c" is correct. A social club organized and operated exclusively for the pleasure and recreation of its members, supported "solely" by membership fees, dues, and assessments is exempt from income tax.

Choice "a" is incorrect. An "action" organization may lose its exempt status due to excessive lobbying. "Excess lobbying expenditures" are defined as the greater of the excess of lobbying expenditures over the lobbying nontaxable amount, or the excess of grass roots expenditures over 25% of the lobbying nontaxable amount.

Choice "d" is incorrect. An organization operated primarily for the purpose of carrying out a trade or business for profit cannot claim tax exemption on the ground that all its profits are payable to exempt organizations. It must rely on its own activities of an exempt nature to gain tax exemption. A feeder organization is taxable on its entire income, not just the portion it designates as its unrelated business income.

Choice "b" is incorrect. An organization whose purpose is to foster national or international amateur sports competition may qualify as an exempt organization only if none of its activities involve the providing of athletic facilities or equipment.

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