Not the IRS’s first rodeo

In a private letter ruling, the IRS determined that a member-based organization that conducts rodeo events and seeks to “raise the standards of cowboy contests” doesn’t qualify for tax-exempt status under Internal Revenue Code Section 501(c)(3). Notably, the organization wasn’t a “qualified amateur sports organization” but rather was a professional rodeo organization, and the group failed to meet both the organizational and operational tests required for tax exemption under the tax law and relevant regulations. (PLR 201706019)

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