- 9 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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