IHC Group, Inc. - Page 19




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          and (4) no substantial part of its activities consists of                   
          political or lobbying activities.  See Fla. Hosp. Trust Fund v.             
          Commissioner, 103 T.C. 140, 145 (1994), affd. 71 F.3d 808 (11th             
          Cir. 1996); Am. Campaign Acad. v. Commissioner, 92 T.C. 1053,               
          1062 (1989).                                                                
               Qualification as an organization described in section                  
          501(c)(3) not only provides an exemption from Federal income                
          taxes, but also generally permits the organization to solicit and           
          accept donations which normally are deductible by the donor                 
          against his or her Federal taxes.  See sec. 170(c); Bob Jones               
          Univ. v. United States, 461 U.S. 574, 577-578 (1983).  With a few           
          minor differences, the organizations and requirements listed in             
          section 170(c)(2) are virtually identical to those described in             
          section 501(c)(3).  With limited exceptions not here relevant,              
          organizations described in the other paragraphs of section 501(c)           
          are not eligible to receive tax-deductible contributions.                   
          In the event the Commissioner determines that an                            
          organization does not qualify for tax-exempt status, the                    
          organization may (after exhausting its administrative remedies)             
          seek judicial review of the matter.  Section 7428(a) confers                
          jurisdiction on the Tax Court, among other courts, to make a                
          declaration with respect to the initial or continuing                       
          qualification of an organization as an organization described in            
          section 501(c)(3). See Houston Lawyer Referral Serv., Inc. v.               






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