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permit.” Petitioner’s stated purposes thus are consistent with
those of any museum.
Respondent contends that, notwithstanding petitioner’s
stated purposes, one of petitioner’s actual purposes is to funnel
tax-deductible contributions to the University. For support,
respondent quotes Christian Manner Intl., Inc. v. Commissioner,
71 T.C. 661, 668 (1979), which states: “It has been recognized
* * * that an organization engaged in a single activity may have
more than one purpose in conducting the activity. So we must be
concerned with both the actual as well as the stated purposes for
the existence of the organization and the activities it engages
in to accomplish those purposes.” We reject respondent’s
contention that petitioner's actual purpose is to funnel tax-
deductible contributions to the University. We see nothing
improper about an educational organization's having as one of its
purposes the receipt of tax-deductible contributions and the use
of those contributions to pay ordinary and necessary business
expenses. In addition, we find Christian Manner International
readily distinguishable from the present case. In Christian
Manner International, the founder of a nonprofit corporation
wrote books that advanced a purportedly religious message and
received proceeds from the sale of the books. The Court
concluded that the corporation’s activities resembled ordinary
commercial publishing practices and that the corporation’s
principal purpose was commercial in nature. In the present case,
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