IRS: The words "open source software" suggest a for-profit business

These organizations are requesting either 501(c)(3) or 501(c)(6) exemption in order to collaboratively develop new software. The members of these organizations are usually the for-profit business or for-profit support technicians of the software.[1]

[1]http://democrats.waysandmeans.house.gov/sites/democrats.ways...