EXHIBIT A
(COPY OF A LETTER FROM ) TREASURY DEPARTMENT Commissioner of Internal Revenue Washington, D. C.
IT: P: T: 1 LLA November 26, 1940
The Imperial Council, A.A.O.N.M.S. c/o Robert P. Smith 815 Fifteenth Street, N. W. Washington, D. C.
Sirs:
Reference is made to the evidence submitted in support of your claim to exemption from the Federal employment tax of your organization and your subordinate temples, in connection with which it is deemed advisable to first determine your status for Federal income tax purposes.
It is the opinion of this office, based upon the evidence presented, that you and your subordinate temples appearing in the list submitted by Robert P. Smith and covered by an affidavit of November 16, 1940, are exempt from Federal income tax under the provisions of Section 101 (3) of the Internal Revenue Code and the corresponding provisions of prior revenue acts.
Accordingly, you will not be required to file returns of oncome unless you change the character of your organization, the purposes for which you were organized, or your method of operation or the operation of your subordinate temples. Any such changes in your form of organization or method of operation or in the subordinate temples referred to herein, should be immediately reported by you to this Bureau in order that the effect of such changes upon your present exempt status may be determined.
You should furnish the Bureau annually on the calendar-year basis lists in quadruplicate showing only the names and addresses of any temples which were chartered during the calendar year and the names and addresses of any temples which for any reason ceased to exist. Such annual lists should be accompanied by a statement sworn to by one of your principal officers as to whether or not the information heretofore submitted by you and on which this ruling is based is applicable in all respects to the new
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temples appearing on the lists and should be forwarded so as to reach this office not later than February 15th of the following year.
Since any organization which is exempt from Federal income tax under the provisions of Section 101 of the Internal Revenue Code also is exempt from the capital stock tax pursuant to the express provisions of Section 1201(a)(1) of the Internal Revenue Code, you and your subordinate temples will not be required to file capital stock tax returns for future years so long as the exemption form income tax is effective.
The determination of your status and that of your subordinate temples for Federal employment tax purposes will be made the subject of a separate communication.
A copy of this ruling will be submitted to the collectors of internal revenue for the various districts in which you and your subordinate temples are located.
By direction of the Commissioner.
Respectfully,
/s/ Wm. Sherwood Acting Deputy Commissioner
Updated MAR 93 3-9
EXHIBIT B Department of the Treasury
Internal Revenue Service WASHINGTON DC 20224 Date: In reply refer to April 29, 1971 T:MS:EO:R:1
The Imperial Council of the Ancient Arabic Order of the Nobles of the Mystic Shrine for North America 323 North Michigan Avenue Chicago, Illinois 60601
Gentlemen:
We have considered your application to modify your group exemption of November 26, 1940, to the extent of holding you exempt under new Section 501 (c)(10) of the Internal Revenue Code of 1954, as amended by the Tax Reform Act of 1969; and to the extent of holding two additional categories of your subordinates: namely, Imperial Council Sessions (sometimes referred to as Convention Corporations) and Shrine Associations; exempt as organizations described in Section 501 (c)(10).
In our ruling dated November 26, 1940, you and your subordinate Temples appearing on the list submitted at that time were held to be exempt from Federal income tax under the provisions of Section 101 (3) of the Internal Revenue Code of 1939, now Section 501 (c)(8) of the Internal Revenue Code of 1954. Our ruling of November 26, 1940 was amended in our supplemental group ruling of March 14, 1966, to provide, in effect, that contributions to you and your subordinate Temples were deductible but only if to be used for exclusively charitable purposes. On the basis of information that you have supplied periodically, the list of Temples has been brought up to date and we have issued supplementary rulings holding those current Temples exempt.
Based on the information supplied we rule that effective January 1, 1970, you and your subordinate Temples are recognized as being exempt under new Section 501 (c)(10) of the Code. This portion of our ruling is to be applied without retroactive effect.
Updated MAR 93 3-10 EXHIBIT B
The Imperial Council of the Ancient -2- Arabic Order of the Nobles of the Mystic Shrine of North America
Based on the information supplied, we also rule that your subordinate Imperial Council Sessions that are named in the group exemption roster you submitted with your request for modification and your subordinate Shrine Associations that are named in both the group exemption roster you submitted with your request for modification and in your recent request for a supplemental group ruling are exempt from Federal Income Tax under new Section 501 (c)(10) of the Code.
This ruling does not extend to any subordinate unit which has previously received a ruling or determination letter holding it not exempt. Its qualifications to be included in this group ruling must be separately established.
Each of your subordinate Imperial Council Sessions and subordinate Shrine Associations is required to file Form 990, Return of Organization Exempt From Income Tax, if its annual gross receipts are normally more than $5,000 [revised to $25,000]. If filing is required, and if you do not include them in a group return, each must file the Form 990 by the 15th day of the 5th month after the end of its annual accounting period.
Your subordinate Imperial Council Sessions and subordinate Shrine Associations are not required to file a Form 1120 income tax return. However, if they are subject to tax on unrelated business income under Section 511 of the Code, they must file Form 990-T.
Your subordinate Imperial Council Sessions and subordinate Shrine Associations are liable for social security taxes under the Federal Insurance Contributions Act and, if they employ four or more individuals, for the tax under the Federal Unemployment Tax Act.
Individuals may deduct contributions to your subordinate Imperial Council Sessions and subordinate Shrine Associations, as provided in Section 170 of the Code, if the contributions are for the charitable purposes specified in Section 170 (c)(4) of the Code. Bequests, legacies, devises, transfers, or gifts to or for the use of these subordinates are deductible for Federal estate and gift tax purposes under Sections 2055, 2106, and 2522 of the Code if they are for the charitable purposes specified in Sections 2055 (a)(3), 2106 (a)(2)(A)(iii), and 2522 (a)(3) of the Code.
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EXHIBIT B
The Imperial Council of the Ancient -3- Arabic Order of the Nobles of the Mystic Shrine for North America
To the extent that this ruling is inconsistent with them, it modifies our ruling issued to you on November 26, 1940, and March 14, 1966.
You should advise each of the subordinates of the provisions of this ruling, including the requirement for filing information or other returns.
Next year, within 45 days after your annual accounting period closes, please send us two copies of the following information about your subordinates:
1. A statement describing all changes during the year in the purposes, character, or method of operation of your subordinates.
2. A list showing the name, employer identification number (if the subordinate is required to file Form 990), and mailing address, including ZIP Code, of each subordinate on your group exemption roster that during the year:
a. changed its name or address; b. was deleted from the roster; or c. was added to the roster.
A directory of subordinates may be substituted for this list if it includes the required information and identifies the affected subordinates according to the three categories above.
3. For subordinates added to the roster, a letter signed by one of your principal officers containing or attaching;
a. a statement that the information upon which your present group exemption letter is based applies to the new subordinates;
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The Imperial Council of the Ancient -4- Arabic Order of the Nobles of the Mystic Shrine For North America
b. a statement that each has given you written authorization to add its name to the roster; and
c. a list of those to which the Service previously issued separate rulings or determination letters relating to exemption.
4. If applicable, a statement that your group exemption roster did not change during the year.
The District Director, Chicago, Illinois, which is your key district for exempt organization matters, is being advised of this action.
Sincerely,
Linder Hamblen Director, Miscellaneous and: Special Provisions Tax Division
Updated MAR 93 3-13
EXHIBIT C
MEMORANDAM
TO: District Director May 29, 1973 Atlanta, Georgia DIS. DIR. INT. REV From: National Office ATLANTA
Subject: Columbia Shrine Club of Columbia, S. C.
This is in reply to your request for technical advice dated January 12, 1972, in which you indicated that you could find no basis for recognizing the exempt status of the Columbia Shrine Club of Columbia, S. C. under any Section of the Internal Revenue Code, including Sections 501(c)(4), 501(c)(7), or 501 (c)(10).
The Club has applied for recognition of exemption under Section 501(c)(7) of the Internal Revenue Code. On June 29, 1970, you proposed to deny recognition of exemption under Section 501(c)(7) of the Code since the Club had constructed a club house and was carrying on social and recreational activities for the benefit of its members and in doing so had solicited patronage from the general public. The funds so obtained served to reduce the cost of operating the club. It was concluded that these activities resulted in the inurement of income to the benefit of members in violation of Section 501(c)(7) of the Code. A district office conference was held and you proposed to affirm your denial of recognition of exemption. The case was submitted to the National Office under the technical advice procedures since the case was unagreed and the organization desired a National Office Conference. The case was subsequently returned to you for consideration of the Club’s status as an integral activity of its Temple and for consideration of its status under Sections 501(c)(4) and 501(c)(10) of the Code.
The information furnished shows that the Club was formed in May 1965, as a voluntary unincorporated association formed for social purposes, the promotion of good fellowship among the members of the Shrine and the furthering of interests of said fraternity in the area served.
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District Director Atlanta, Georgia
The Club was chartered under the authority of the Potentate of Omar Temple, constituted and chartered by the Imperial Council of the Ancient Arabic Order of the Nobles of the Mystic Shrine for North America. Its constitution and charter state that the Club and its members shall be under the direct jurisdiction and control of Omar Temple and shall adhere to the bylaws, rules, and regulations of said Temple and to the laws and edicts of the Imperial Council. Any Noble in good standing in a legally constituted and chartered temple and residing in the jurisdiction of the Omar Temple is eligible for membership. Candidates for active membership are elected or excluded by ballot of the active members of the Club. Discontinuance of active membership in the Fraternal Order of the Shrine for any reason automatically terminates membership in the Club.
Article IV of the Club’s constitution provides that the Club shall be under the management of a Board of Directors to consist of 22 members, who shall be elected by the active members of the Club in good standing, in such manner and for such term as may be prescribed in the constitution and in the bylaws of the Club, provided, however, that for cause shown the Potentate of Omar Temple may suspend the authority of the officers and the Board of Directors to manage the affairs of the Club and may appoint temporary officers and Directors for such purpose. The Club shall have a Chairman of the Board. A President, Vice President, Secretary and Treasurer shall be elected by the Club membership to serve for one year or more until their successors are duly elected. The Club’s bylaws provide in Article 1, Section 4, that any member may withdraw or resign from the Club at a duly constituted meeting or by notice in writing to the President or Secretary of the Club.
Article V of the bylaws provides that the Potentate of Omar Temple may suspend the bylaws and conduct the affairs for such time and for such purposes as the nature of the circumstances warrant.
Updated MAR 93 3-15
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District Director Atlanta, Georgia
The Club’s application for exemption states that it provides facilities for recreation and fellowship of its members. The facilities include a swimming pool, a large club house for dances and a snack bar. Its financial statements show receipts from fund raising events such as dances, bingo’s and rental of the Club facilities. A few of these events were advertised as being open to the public. Attendance at these functions is generally open to all Shriners whether they are members of the Club or not. Funds were not expended for the building and maintenance of Club facilities.
In a letter dated December 1, 1969, a representative of the Club states that the Club functions to assist the Shrine and its various units in their fund raising activities. It also functions as a social club to provide entertainment and enjoyment for its members. All profits, other that from specific fund raising activities for the Shriner Crippled Childrens Hospital, are turned over to a Shrine Club Holding Corporation to apply to building and facility cost and to debt service. The sole function of the Holding Corporation is the holding and management of the property of the Columbia Shrine Club. The statement further indicates that the reason for the formation of the Club and for construction of facilities by the Corporation was to provide some organization to the Columbia Area Shriners and to provide a place for their various units to meet and conduct fund raising activities. In connection with the fund raising functions, the various units of the Shrine usually handle the proceeds, which are not run through the Club’s records except for rents, and send the net funds to the Crippled Childrens Hospital either directly or through the Temple.
A 1965 letter to all Nobles in the area for the purpose of interesting new members in the Club indicates that with its contemplated facility, they could have projects to raise funds for their hospital work and could have Masonic Nights for Brother Master Mason and encourage them to take the Scottish and York Rite degrees and then join the Shrine.
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District Director Atlanta, Georgia
The letter states plans were made to have a large enough building to hold joint ceremonials and possibly a Southeastern Convention. It also indicates the Club is to serve as a family club with swimming pool, picnic and recreation area, and dining room.
A conference was held in this office on August 30, 1972, with Mr. Fred E. Stuart, C. P. A. Mr. Stuart at that time indicated that the reason for the existence of the Shrine is for fraternal purposes, fellowship, and recreation of members, and to raise funds for benevolences (Children's Hospitals). He further stated that the Club was an activity of the Shrine under Omar Temple and was not a separate organization. Subsequently, an affidavit to this effect was submitted over the signature of George M. Saunders, Imperial Recorder of the Imperial Council.
On December 6, 1972, a meeting was held in this office with Mr. Saunders and other representative of the Imperial Council to explore the question of the recognition of exemption for all Shrine Clubs. Additional information and a legal brief were submitted for our consideration after this meeting.
Information furnished by the Imperial Council indicates that the reason for the formation of Shrine Clubs is to provide a way where Nobles may meet and fraternize with each other in local areas are usually some distance from the Shrine Temple itself. The vast majority of Shrine Clubs usually conduct weekly or monthly dinner meetings of the Nobles of the particular Shrine Temple in the local area. However, in larger Shrine Clubs in bigger cities, the Clubs have such activities as picnics, dances, fish fries, corn boils, ladies nights, and similar type activities. They also raise funds for charitable purposes through circuses, sporting events and paper drives.
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District Director Atlanta, Georgia
They may also form motorized units to participate in Temple parades and pageants. The Shrine Clubs are also an important source in the sponsorship of underprivileged children to the Temple circuses and help to inform the Temple of children in the local area needing orthopedic or burn care and treatment. The Imperial Council also indicates that Shrine Clubs are a good source in bringing Masons in the local area into their particular Shrine Temple, which enhances the over all Shrine program.
A pamphlet entitled “A Short History of the Shrine contains the following information:
During the depression era we found it was not only difficult to get new members, but it was also a problem to hold the ones we had on the rolls. It was found to be an advantage in the local Temples to take the Shrine and Shrine activities out into the towns in the Temple’s jurisdiction as well as into the city which was the seat of the Temple. It took some time to get this program organized, but from this thought came the idea of organizing Shrine Clubs throughout the Temple's jurisdiction and today these Shrine Clubs number nearly 2,500 and from their activities these Shrine Clubs produce a large portion of the new petitions for the Temples. Shrine Clubs are organized by, and always remain under the control of the Potentate of the Temple. They have been found to be great assets of the Temple when they are properly directed by the Temple.
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District Director Atlanta, Georgia
A legal brief furnished to this office indicates that the Imperial Council believes that the Shrine Clubs are integral activities of the Temples and do not have separate legal existence which would require them to qualify for recognition of exemption on their merits. The brief points out that the structural characteristics of an association taxable as a "corporation" include, among others, an objective to carry on a trade or business for profit and divide the gains therefrom and privilege of limited liability for the owners. The brief indicates that a "profit motive" is absent in the Shrine Club. Further, since the Shrine Temple exercises legal and practical control over the unincorporated and incorporated Shrine Clubs, it has the ultimate command over the legal rights and responsibilities which attend control. Thus, it may be the ultimate respondent with respect to other attributes of Iocal law including tort or contractual liability for acts of the members.
First, we considered the question of whether Columbia Shrine Club is an association for purposes of determining whether it should have to qualify for recognition of exemption as a separate legal entity.
Section 301.7701-2(a)(1) of the Income Tax Regulations provides that the term "association" refers to an organization whose characteristics require it to be classified for purposes of taxation as a corporation rather than as another type of organization such as a partnership or a trust. These characteristics include (1) associates, (2) an objective to carry on business and divide gains therefrom, (3) continuity of life, (4) centralization of management, (5) liability for corporate debts limited to corporate property, and (6) free transferability.
Section 301.7701-2(a)(2) of the regulations provides that since associates and an objective to carry on, in part, business for joint profit are essential characteristics of all organizations engaged in business for profit (other than the so-called one-man corporation and the sole proprietorship), the absence of either of these essential characteristics will cause an arrangement among co-owners of property for the development of such property for the separate profit of each not to be classified as an association.
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District Director Atlanta, Georgia
Characteristics common to trusts and corporations are not material in attempting to distinguish between a trust and an association, and characteristics common to partnership and corporations are not material in attempting to distinguish between an association and a partnership.
Section 301.7701-2(a)(3) of the regulations provides an unincorporated organization shall not be classified as an association unless such organization has more corporate characteristics than noncorporate characteristics. In determining whether an organization has more corporate characteristics than noncorporate characteristics, all characteristics common to both types of organization shall not be considered.
In the case of Philadelphia & Reading Relief Association, 4 BTA 713 (1926), the U.S. Board of Tax Appeals found that a voluntary unincorporated association, composed of employees of a railroad company, organized for the purpose of establishing and managing a relief fund for the payment of benefits to its members, in case of sickness, accident, or death, whose business was conducted by executive officers under the supervision of an advisory committee, a majority of which were elected by the members of the association, and otherwise doing business under the general form and mode of procedure of a corporation, was an "association”, within the meaning of Section 1 of the Revenue Act of 1918.
The issue in this case is whether a Shrine Club is an association or a mere formless aggregation of individuals having no status as an entity separate and distinct from its members or the Temple to which they belong. AccordingIy, in applying the test of Section 301.7701-2(a)(3) of the regulations to determine whether a Shrine Club has more corporate characteristics than noncorporate characteristics, all of the corporate characteristics must be considered, and a Shrine Club would not be classifiable as an association unless it is shown to possess a preponderance of corporate characteristics.
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District Director Atlanta, Georgia
One of the six corporate characteristics referred to in the regulations, an objective to carry on business and divide the gains therefrom, would not be relevant or apt in determining whether an unincorporated nonprofit organization is classifiable as an association. In cases involving nonprofit organizations, however, the Service considers that this test of Section 301.7701-2 (a)(2) of the regulations is satisfied if the participants have an objective to carry on, jointly, activities in furtherance of the purposes for which the organization was formed.
The Columbia Shrine Club is a membership organization, and therefore has associates. Its members have an objective to carry on, jointly, activities in furtherance of the purposes for which the Club was formed. The Club has continuity of life, since the expulsion or resignation of a member does not cause a dissolution of the organization. The Club has centralization of management in the hands of the Board of Directors and the elected officers. This is subject to supervision by the parent Temple in that the Temple can dissolve the Club. This authority by the Temple, however, is not sufficient to negate the authority given by the membership and the Temple to the Directors and Officers to make the management decisions necessary to the conduct of the activities for which the Club was formed. Since four of the six corporate characteristics are present in the Club, we think that the Columbia Shrine Club is an “association” within the meaning of Section 301.7701-2(a) of the regulations, and must establish its right to recognition of exemption from Federal income tax.
The question of Columbia Shrine Club’s entitlement to recognition of exemption must be considered next.
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District Director Atlanta, Georgia
Section 501(c)(10) of the Code provides for the exemption from Federal income tax of domestic fraternal societies, orders, or associations operating under the lodge system the net earnings of which are devoted exclusively to religious, charitable, scientific, literary, educational, and fraternal purposes, and which do not provide for the payment of life, sick, accident, or other benefits.
Section 1.501(c)(10)-1 of the regulations provides that an organization will qualify for exemption under Section 501(c)(10) if it is a domestic fraternal beneficiary society order, or association, described in Section 501(c)(8) and the regulations thereunder except that it does not provide for the payment of life, sick, accident, or other benefits to its members.
Section 1.501(c)(8)-1 of the regulations provides that a fraternal beneficiary society is exempt from tax only if operated under the "lodge system” or for the exclusive benefit of the members so operating. “Operating under the lodge system” means carrying on its activities under a form of organization that comprises local branches, chartered by a parent organization and largely self-governing, called lodges, chapters, or the like.
The Imperial Council of the Ancient Arabic Order of the Nobles of the Mystic Shrine and its Temples have been recognized as exempt from Federal income tax as a fraternal society operating under the lodge system under Section 501(c)(10). Based on the information furnished, it appears that Shrine Clubs were set up to carry out activities of the fraternal society since they were instituted to fulfill the needs of their creating Temple. Since the creating Temple maintains control over its Shrine Clubs through its ability to grant and revoke charters, Shrine Clubs function as part of the lodge system. Therefore, it is our conclusion that Shrine Clubs are operating as fraternal societies under the lodge system and are entitled to recognition of exemption under Section 501(c)(10) of the Code.
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District Director Atlanta, Georgia
Since the Imperial Council and its Temples have not included the Shrine Clubs in the group ruling, the Service will have to consider each Shrine Club individually as it files an application for recognition of exemption.
In the instant case, the Columbia Shrine Club was formed and chartered by its parent Temple to carry out fraternal activities. Its activities include social activities for members which are fraternal in nature. It is involved in raising funds for Crippled Children's Hospitals which is an activity encouraged by its parent Temple. The use of funds for the erection and maintenance of a building as a place to carry out its activities and to provide facilities for related lodges is an expenditure in furtherance of its fraternal purposes. Although information contained in the file indicates that some of its early social activities may have been open to the public, it does not appear that this activity was substantial. Therefore, it is concluded that the Columbia Shrine Club is entitled to recognition of exemption under Section 501(c)(10) of the Code. Prior to the enactment of Section 501(c)(10), it would have been entitled to recognition of exemption under Section 501(c)(8) of the Code.
-END-
Updated MAR 93 3-23
EXHIBIT D
Internal Revenue Service WASHINGTON, DC 20224 Date: OCT 12 1973 I In reply refer to: ______T: MS; EO; R:1-2 The Imperial Council of the Ancient Arabic Order of the Nobles of the Mystic Shrine for North America 323 North Michigan Avenue Chicago, Illinois 60601
Gentlemen:
This refers to your request dated September 5, 1973, for a ruling concerning whether shrine clubs may be added to the group ruling issued to you under Section 501(c)(10) and whether your subordinate temples can be considered to be central organizations with respect to shrine clubs for the purposes of filing annual information returns.
The information submitted by you discloses your temples are subordinate organizations which you control and that shrine clubs are subordinate organizations which the temples set up and control. For purposes of your request, the operations of and the organizational nature and documents of the Columbia Shrine Club are considered to be representative of shrine clubs which your subordinate temples have established.
Based on the information you supplied in your request dated September 5, 1973, and the information you previously submitted in connection with the question of the qualification for recognition of exemption of the Columbia Shrine Club, we have modified the group ruling issued to you dated April 29, 1971, to the extent that your subordinate shrine clubs are now exempt under Section 501(c)(10) under that group ruling letter. The provisions of our letter dated April 29, 1971, otherwise remain in effect. In addition, we have determined your subordinate temples constitute central organizations with respect to shrine clubs for purposes of Section 6033 since status of shrine clubs as subordinates is established only through temples setting up and controlling shrine clubs. Thus, each subordinate temple may file a group return described in Section 1.6033-2(d) on behalf of subordinate shrine clubs which it has set up and controls and which are included in the group ruling issued to you.
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The Imperial Council of the Ancient Arabic Order of the Nobles of the Mystic Shrine for North America
Since at this time a roster of your shrine clubs has not been submitted, you should supply a complete roster of your subordinate shrine clubs when you supply the information needed to maintain your group ruling. This roster of subordinate shrine clubs must include the information required by section 6 of Revenue Procedure 72-41, 1972-2 C. B. 820, at 821, for new subordinates to be included in a group ruling. Failure to submit this information would cause us to consider your shrine clubs not to be covered by your group ruling. However, if there are some shrine clubs for which you have not obtained all of the required information by the time of your next required submission, such shrine clubs could be included in your group ruling by a later submission. If at the time of your next required submission little additional time is needed to supply complete information as to all shrine clubs, you should request an extension of time to supply the information at the time of your next required submission.
We are sending a copy of this letter to your key District Director, Chicago, Illinois.
Sincerely yours,
Milton Cerny Chief, Rulings Section 1 Exempt Organizations Branch
Updated MAR 93 3-25 EXHIBIT E
Excerpt From
CONGRESSIONAL RECORD – SENATE
December 9, 1969 S 16262
MR. HANSEN, Mr. President. I should like to ask the distinguished senior Senator from Delaware his view as to the application of the unrelated business income tax in the case of fraternal beneficiary societies -- such as the Shriners, which is well known for their support of crippled children's hospitals -- where they sponsor football games or present a Shrine circus. In this case will they be exempt from unrelated business income treatment on income from activities of this type?
MR. WILLIAMS of Delaware. The answer is ‘Yes’. The unrelated business income tax does not apply to income from activities which are not carried on by such an organization on a regular basis – that is, incidental or sporadic activities, such as the Senator has mentioned, the Shrine circus or annual football game, and similar activities would not constitute regularly engaging in a business.
MR. HANSEN. The fact that the Shrine may carry on, for a week or so each summer, a Shrine circus, even though this may be something that is done year after year, would still not cause the income from the circus to be subject to the unrelated business income tax?
MR. WILLIAMS of Delaware. The answer is ‘Yes’. Our committee considered that very problem. We are confident that these activities are not taxed under the bill.
MR. LONG, Mr. President. I affirm what the Senator from Delaware said. That was the intent of the committee.
MR. WILLIAMS of Delaware. I do not think there is any question about it.
MR. HANSEN, Mr. President. I thank the distinguished chairman of the committee and the distinguished ranking minority member.
MR. CURTIS, Mr. President, as a matter of fact, there was a direct vote in the Finance Committee on this matter, and the committee voted not to tax such activities as circuses and other such activities.
Updated MAR 1993 3-26