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In particular, respondent emphasizes that the University requires
all of its students to visit the museum as part of a required
freshman course and as part of several elective courses.
Petitioner contends that the University’s requirement that
students visit the museum is not problematic. Petitioner
emphasizes that other schools may require students to visit
museums as part of their academic curricula and that whether
those museums are located on or off campus does not affect the
tax-exempt status of the schools imposing the requirement.
We conclude that any benefit the University derives from
petitioner’s location is merely incidental. See Kentucky Bar
Found., Inc. v. Commissioner, 78 T.C. 921, 926 (1982).
Respondent has not cited, nor have we found, any cases that
suggest that the location of an organization may affect its
eligibility for exempt status. Moreover, approximately 80
percent of all visitors to the museum are not affiliated with the
University. Evidently, the location does not deter public
visitors.
F. Enhancement to Reputation
Respondent contends that petitioner’s name and location
serve to “enhance the University’s educational and spiritual
reputation” and thus confer a private benefit on the University.
While we agree that the University receives an intangible benefit
from petitioner’s name and location, we conclude that the benefit
is minimal and incidental. See id.
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