Bob Jones University Museum and Gallery, Inc. - Page 9

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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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