California Revenue & Taxation Code
Cal. Rev. & Tax. Code § 23737
In the case of any organization described in Section 23701d to which this article is applicable, exemption under Article 1 (commencing with Section 23701) shall be denied for the taxable year if the amounts accumulated out of income during the taxable year or any prior taxable year and not actually paid out by the end of the taxable year—
# (a)
Are unreasonable in amount or duration in order to carry out the charitable, educational, or other purpose or function constituting the basis for such organization’s exemption under Section 23701d; or
# (b)
Are used to a substantial degree for purposes or functions other than those constituting the basis for such organization’s exemption under Section 23701d, or
# (c)
Are invested in such a manner as to jeopardize the carrying out of the charitable, educational, or other purpose or function constituting the basis for such organization’s exemption under Section 23701d.
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