Rev. Rul. 56-570

Section 4233(a)(1) of the Internal Revenue Code of 1954 provides, in subparagraph (A) thereof subject to the exceptions set forth in subparagraph (C), an exemption from the admissions tax for any admissions all the proceeds of which inure exclusively to the benefit of certain religious, educational, or charitable organizations. Subparagraph (C) provides, in part, that the exemption will not apply in the case of admissions to any athletic game or exhibition unless the proceeds inures exclusively to the benefit of an elementary or secondary school or unless, in the case of an athletic game between teams composed of students from elementary or secondary schools, or colleges, the entire gross proceeds from such game inure to the benefit of a hospital for crippled children. Held, the term `teams composed of students from elementary or secondary schools, or colleges,' does not include teams which are composed of, or which include, players who at the time of the game have graduated from their respective schools or colleges and are no longer students thereof. Accordingly, the exemption does not apply in the case of an athletic game between teams composed, in whole or in part, of players who have graduated and left their respective schools or colleges where the proceeds from such game inure to the benefit of a hospital for crippled children.