Not as simple as that. Read the thread on the club BB. Not all the money was donated. Some came from the club general fund. Get the wrong IRS inspector and that could be deemed as 'profit' rather than 'surplus operating income' or whatever term you use there.
Start purchasing assets with that money and it easily be regarded as a 'business'. Spend the money on rentals, or any 'write-offs' and its okay as the IRS gets their $$ from the lessee.
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