Portal:United States Internal Revenue Service

“ Rights to commercially exploit the program were held by EST, Inc., a for profit corporation. In 1973 a franchise system was created whereby EST, Inc., would relinquish its operations in a particular geographic area to a local tax-exempt corporation. EST, Inc., through one or more intervening corporations, would supply qualified personnel to staff the organization, furnish materials needed to conduct the organization's activities, and assure that the organization conducted its activities in conformity with the standards of EST, Inc. ”

“ C. Overview of Inurement/Private Benefit Issues in IRC 501 (c) (3) /est of Hawaii 6. Problems Involving Multiple Entities C. More Complex Cases 2. est of Hawaii est of Hawaii v. Commissioner, 71 T.C. 1067 (1979) , aff'd, 647 F.2d 170 (9th Cir. 1981) , involved the marketing of a self realization program developed by Werner Erhard and known as "Erhard Seminar Training." ”