7
is being furthered is one of fact. Christian Stewardship
Assistance v. Commissioner, 70 T.C. 1037, 1042 (1978); Christian
Manner International v. Commissioner, 71 T.C. 661, 668 (1979).
The question of whether net earnings inure to the benefit of a
private shareholder or individual is also one of fact. Unitary
Mission Church v. Commissioner, 74 T.C. 507, 514 (1980), affd.
without published opinion 647 F.2d 163 (2d Cir. 1981).
As we consider the administrative record in this case that
has been presented by the parties, we come to the conclusion that
petitioner has failed to carry its necessary burden of proof to
show that it has been and is being operated exclusively for
exempt purposes within the meaning of section 501(c)(3). As is
made clear by the statement in petitioner's application for
exemption, which we have quoted, the primary purpose of the
organization is to plant trees, with a secondary purpose to
promote and establish the industry of papermaking, perhaps using
alternative materials other than paper from wood pulp.
Petitioner has not shown that its objective to encourage the
papermaking industry is a public and charitable purpose.
Further, there is no showing in this record that
petitioner's net income does not serve private purposes and does
not accrue to the benefit of individuals. What information is
provided--and we concede that this present petitioner seems to be
only in the initial or "shell" stages--is that John Stahl, his
wife, and children are afforded rent-free housing on petitioner's
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