Finally, many unincorporated associations
find they have trouble with potential lenders who are
more comfortable dealing with corporations than with
unincorporated associations. Practically speaking, for
an unincorporated association to qualify for federal tax
exemption under § 501(c)(3) (which is, after all, the
purpose of this paper) the unincorporated association
must make itself look and act quite a bit like a
nonprofit corporation through adoption of a governing
instrument with the requisite provisions for exemption