The IRS has historically found that organizations engaged in scrutinizing other journalists are engaged in "educational" activity. In Revenue Ruling 74-615, the IRS ruled that a non-profit organization whose "purpose is to educate the public concerning the accuracy and fairness of news coverage by local newspapers" qualified for a 501(c)(3) exemption:
By investigat[ing] the newspapers' practices and publishing the results of its analyses, the organization is helping to insure the public has full and fair newspaper reporting.
It has been historically recognized that the conduct of factual inquiries on subjects of benefit to the public and the dissemination of the information so developed is educational in the charitable sense. [FN1]
Similarly, in Revenue Ruling 79-26, the IRS ruled that a non-profit organization dedicated to evaluating the quality of local broadcasting was tax exempt. [FN2]
It is not clear if the IRS's perspective on these "meta-journalism" non-profits extends to other forms of watchdog journalism, or just reflects an institutional perception that the media require oversight. However, a news organization engaging in oversight of a particular industry or branch of government should consider emphasizing the public benefit of that activity.
1 Rev. Rul. 74-615, 1974-2 C.B. 165.
2 Rev. Rul. 79-26, 1979-1 C.B. 196.