Revenue Ruling 72-513 involves a college newspaper that provided training for students in various aspects of publishing, editing, and managing a daily newspaper, including coverage of political news and the preparation of editorial comments. n56 Although several of the university's professors served as advisors to the newspaper staff, a majority vote of the student editorial editors determined the editorial policy. n57 From time to time, editorials took not only a position on pending or proposed legislation, but also on individual candidates running in a campaign for political office. n58

According to the ruling, these editorials did not violate the political activity prohibition under Section 501(c)(3) for two reasons. n59 First, neither the university administration nor faculty advisors exercised any control or direction over the newspaper's editorial policy. n60 Second, a statement on the editorial pages made it clear that the views expressed were those of the student editors and not of the university. n61

This ruling implies that the school's administration and its students are independent, thus preventing editorial comments from reflecting the views of the institution. The students at Imaginary University, rather than the administration, control the editorial views. As a result, Imaginary University lacks any participation or intervention with this political campaign activity. Therefore, Imaginary University's student newspaper may publish political editorials this fall without violating 501(c)(3) so long as the [*143] editorial views are solely within the control of the students and the students print a statement to that effect on the editorial page.

Neither IRS regulations nor revenue rulings have addressed whether publishing candidate endorsements or political cartoons during a campaign constitutes prohibited political activity has not been addressed by the regulations or revenue rulings. Candidate endorsements and political cartoons differ from editorials in substance and form. However, these methods of editorial expression are "commonly accepted features of legitimate journalism." n62 Accordingly, the publication of candidate endorsements and political cartoons in Imaginary University's school paper should likewise be a decision made solely by the student editorial board and the newspaper should contain a statement clearly delineating it as such. These actions will preclude any opportunity for Imaginary University to participate in a political campaign, thereby avoiding potential tax implications.