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property that was deeded to it by John Stahl; furthermore, it
appears that petitioner took over the burden of debts owed on the
property as well as personal debts of John Stahl and his
proprietorship printing venture. Petitioner has simply failed to
show in this record that it is operated exclusively for exempt
purposes. The implication from the scanty record presented is
rather to the contrary. The rather vague references to the
development of alternative papermaking resources from materials
other than wood pulp, and the projects to secure Government
assistance in furthering such projects, all tend to be in aid of
the papermaking and printing industries, as opposed to a
nonprofit public purpose.
In cases like this one, the courts have considered the
question of exemption under section 501(c)(3) before deciding
whether the organization constitutes a church within the meaning
of the Code. Only in the event the Court finds that petitioner
qualifies for exemption under section 501(c)(3) must the Court
further decide whether petitioner is a church. The Basic Unit
Ministry of Alma Karl Schurig v. United States, 511 F. Supp. 166
(D.D.C. 1981), affd. per curiam 670 F.2d 1210, 1212 (D.C. Cir.
1982); American Guidance Found. v. United States, 490 F. Supp.
304, 306 (D.D.C. 1980), affd. without opinion __ F.2d __ (D.C.
Cir. 1981). Since we have held that petitioner does not qualify
as an exempt institution under the provisions of section
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