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organized and operated exclusively for * * * charitable * * *
purposes, * * * no part of the net earnings of which inures to
the benefit of any private shareholder or individual.” (Emphasis
added.) Thus, the organization must be both organized and
operated exclusively for at least one of the stated purposes.
Sec. 1.501(c)(3)-1(a)(1), Income Tax Regs.
Respondent concedes that once SNI amended its Articles of
Incorporation to delete that one of its purposes was to “find out
where one goes when he or she leaves”, so that the Articles now
reflect that SNI’s activities would be limited to charitable,
religious, educational, literary, and/or scientific purposes, SNI
meets the organizational test. However, respondent asserts that
SNI fails to meet the operational test because SNI has not shown
that it is not operated for the benefit of a private individual;
i.e., David A. Valfer. See sec. 1.501(c)(3)-1(d)(1)(ii), Income
Tax Regs.
We agree with respondent. As stated in the regulations, the
operational test is as follows:
An organization will be regarded as “operated
exclusively” for one or more exempt purposes only if it
engages primarily in activities which accomplish one or
more of such exempt purposes specified in section
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Last modified: May 25, 2011