Rev. Rul. 66-255

Advice has been requested whether an organization created for the purpose of educating expectant mothers and the public in a method of painless childbirth qualifies for exemption from Federal income tax under section 501(c)(3) of the Internal Revenue Code of 1954.

The organization carries out its purpose through: ( a ) public programs of films followed by discussions with doctors and members of the organization; ( b ) presentations on local radio stations; ( c ) meetings conducted by a doctor or a registered nurse for expectant parents; and ( d ) pamphlets, manuals, and books which are distributed to libraries, hospitals, and obstetricians.

Section 501(c)(3) of the Code provides for the exemption from Federal income tax of organizations organized and operated exclusively for educational purposes.

Section 1 .501(c)(3)-1(d)(3)(i)(b) of the Income Tax Regulations provides that the term `educational' for the purposes of section 501(c)(3) of the Code relates to the instruction of the public on subjects useful to the individual and beneficial to the community. An organization may be educational even though it advocates a particular position or viewpoint so long as it presents a sufficiently full and fair exposition of the pertinent facts as to permit an individual or the public to form an independent opinion or conclusion. On the other hand, an organization is not educational if its principal function is the mere presentation of unsupported opinion.

Based upon the facts presented the organization qualifies for exemption from Federal income tax under section 501(c)(3) of the Code.

An organization which considers itself within the scope of this Revenue Ruling must, in order to establish exemption under section 501(c)(3) of the Code, file an application on Form 1023, Exemption Application, with the District Director of Internal Revenue for the internal revenue district in which is located the principal place of business or principal office of the organization. See section 1.501(a)-1 of the regulations.