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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 funds
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