B-210922.1: Jun 27, 1983

YOU HAVE INDICATED THAT AN EARLY RESPONSE ON THE ISSUE OF SECTION 117 IS ESSENTIAL. WE ARE ANSWERING THAT QUESTION FIRST. WE SHALL ISSUE A SEPARATE DECISION TO IRS WHEN WE HAVE DECIDED THE OTHER QUESTIONS POSED. MEANS ANY TRADE OR BUSINESS WHICH IS NOT SUBSTANTIALLY RELATED TO THE EXERCISE OF THE ORGANIZATIONS' CHARITABLE FUNCTION. WE WISH TO POINT OUT THAT THERE MIGHT BE CONSTITUTIONAL PROBLEMS I...

B-210922.1: Published: Jun 27, 1983. Publicly Released: May 6, 1985.

In response to a request from the Internal Revenue Service (IRS), GAO gave its interpretation of a section of legislation pertaining to the implementation and enforcement of IRS rulings against North Dakota tax exempt organizations which have been administering games of chance. GAO does not generally offer opinions on the constitutionality of enacted legislation. However, from its analysis of the...