- 8 - its association with petitioner. Even if none of these factors alone is found to be disqualifying, respondent maintains that their cumulative effect precludes petitioner’s qualification for exempt status. As a preliminary matter, we address respondent’s contention that petitioner has conceded that it furthers a substantial nonexempt purpose. Respondent emphasizes that petitioner’s application for tax-exempt status contained the following statement: “One of the purposes behind the establishment of the organization is to allow for gifts to be made to the museum and art gallery as charitable contributions, whereas no such deduction would be allowed for such contributions if they were given to the University.” (Emphasis added.) We do not agree with respondent that this statement constitutes a disqualifying admission of a nonexempt purpose. The “purpose” of allowing donors to deduct contributions, which presumably induces a larger number and greater amount of contributions to an organization, motivates virtually every organization’s decision to seek exempt status. If that objective precluded an organization from qualifying for tax exemption, few if any organizations would ever satisfy the section 501(c)(3) requirements. More importantly, the sentence in petitioner's application immediately following the one quoted above states: “Contributions to the organization will be used solely for the operation of the museum and art gallery and for acquisition of additional art as available fundsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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