- 16 - We find problematic and reject the notion that enhancement of another entity’s “educational and spiritual reputation” may preclude exempt status. Respondent has not cited, nor have we found, any cases supporting her position. G. Cumulative Effect of These Factors Ultimately, respondent concedes that “most of the individual factors * * * may not appear to result in more than incidental private benefit” but contends that the “cumulative effect” of these factors creates a private benefit. We disagree. Based on our review of the record, we conclude that petitioner satisfies the requirements of section 501(c)(3) in substance as well as in form. Petitioner is a museum, open to the public free of charge, that displays what petitioner claims is one of the greatest collections of religious art in the Western Hemisphere. Respondent has not challenged this claim. With respect to all financial dealings between petitioner and the University, respondent has conceded that petitioner is paying the University fair market value or less. While there is no doubt that the University receives certain benefits from petitioner's existence, these benefits are merely incidental. III. Conclusion Respondent’s arguments ultimately lead to the conclusion that a taxable corporation could never spin off a tax-exempt organization and conduct subsequent financial dealings with it. Because funds raised by a tax-exempt organization generally comePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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