From: Ed Pentz <[log in to unmask]> Date: Thu, 16 Aug 2012 03:48:11 -0500 Hi: Interestingly, this is what the IRS did back in the early 80s. CCC is a NY state not-for-profit but not tax exempt with the IRS as determined by the Tax Court - Copyright Clearance Center v. Commissioner, 79 T.C. 793 (1982). Regards, Ed Pentz