The Revenue Act of 1909 mirrored and expanded
the language from the 1894 act. Under this statute,
tax exemption was granted to "any corporation or association organized and operated exclusively for religious, charitable, or educational purposes, no part of the net income of which inures to the benefit of any private stockholder or individual." This important
addition set forth the idea that tax-exempt charitable
organizations should be free of private inurement—in other words, nonprofit.