Is the Distribution of Materials Necessary or Valuable in Achieving Educational Purposes?

This element of the four-part test set out in Revenue Ruling 67-4 is likely to be met by an organization whose primary activity is the publication of material. As one federal district court has stated, "Certainly there is no better way to capture the attention of a widely dispersed public. The publication of literature is, concededly, the common method in carrying out the religious and educational purposes of any exempt organization." [FN1] More explanation might be required, however, for an organization engaged in various charitable activities that publishes content as just one part of its work.


1 Fides Publishers Ass'n v. United States, 263 F. Supp. 924, 935 (N.D. Ind. 1967).



Subject Area: