1. IRS EXEMPT ORGANIZATIONS HANDBOOK (IRM 7751), § 230.
2. Rev. Rul. 68-371, 1968-2 C.B. 204. A title-holding organization in this position could retain tax-exempt status by appropriately amending its articles of incorporation and other corporate documents.
3. Rev. Rul. 77-429, 1977-2 C.B. 189.
4. IRC § 501(c)(2). This type of organization is to be contrasted with the feeder organization of IRC § 502, which is an entity that carries on a trade or business for the benefit of a tax-exempt organization and is itself not tax-exempt.
5. Rev. Rul. 66-102, 1966-1 C.B. 133.