Although tax exempt organizations are creatures of the state ,it is under the federal law that they seek exemption from tax. Many unqualified organizations have sought and received this exemption. Many abuses and schemes have arisen, in which even qualified organizations have been made parties. The big question is whether the exemption laws are not clear enough or whether they have been lackadaisically enforced. It is this writer's opinion that the law is adequate, and that strict enforcement of the law is all that is necessary to clear up the tax abuses by non-profit organizations which have taken place since the end of World War II.
Edward A. Lebit, Tax Exempt Organizations, 13 Clev.-Marshall L. Rev. 172 (1964)