An essential earmark of an exempt social club is personal contact, commingling and face-to-face fellowship. Members must share interests and have a common goal directed toward pleasure, recreation and similar purposes. Fellowship need not be present between each member and every other member, as long as it is a material part in the life of the organization. A statewide or nationwide organization that is made up of individual members, but divided into local groups, satisfies this requirement if fellowship is a material part of the life of each local group. Example: A flying club is organized by owners and operators of business or personal use aircraft. The club will help members improve their flying abilities and will provide economical flying facilities for members. The club’s sole activity involves members owning, operating and maintaining the aircraft. Because there is little commingling among members for social or recreational purposes, the club does not qualify for exemption under Code section 501(c)(7).
