The quotes from IRS shot that this is not a random rejection, rather a whole policy with thought-out basis. Somebody took time to ridicule open source in legalese.
Its not "ridiculing". Its applying the law and existing precedent to the specific facts presented by Yorba. It may be wrong, but reading the whole letter it seems like its more that Yorba did a poor job at explaining how it met the 501(c)(3) requirements, including when responding to specific inquiries by the IRS.[1]
(It'd be interesting to get the application and other documents and compare them to those of, e.g., the Apache Software Foundation, Mozilla Foundation, and other open-source entities that have gotten 501(c)(3) status and see if its really that the IRS decision here is out of line with other ones in similar areas or if its just Yorba's documentation and explanations that are the issue.)
Comments
Its not "ridiculing". Its applying the law and existing precedent to the specific facts presented by Yorba. It may be wrong, but reading the whole letter it seems like its more that Yorba did a poor job at explaining how it met the 501(c)(3) requirements, including when responding to specific inquiries by the IRS.[1]
(It'd be interesting to get the application and other documents and compare them to those of, e.g., the Apache Software Foundation, Mozilla Foundation, and other open-source entities that have gotten 501(c)(3) status and see if its really that the IRS decision here is out of line with other ones in similar areas or if its just Yorba's documentation and explanations that are the issue.)
[1] http://yorba.org/docs/IRS-determination-letter-final.pdf