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for one or more exempt purposes is a question of fact to be
resolved on the basis of all the evidence in the administrative
record. B.S.W. Group, Inc. v. Commissioner, 70 T.C. 352, 357
(1978); Washington Research Found. v. Commissioner, T.C. Memo.
1985-570. Petitioners have the burden of establishing that the
grounds for denying exemption stated in the final notices of
determination were inadequate. Rule 217(c)(2)(A); Florida Hosp.
Trust Fund v. Commissioner, 103 T.C. 140, 146 (1994), affd. 71
F.3d 808 (11th Cir. 1996).
II. Qualification as “Charitable” Under Section 501(c)(3)
Petitioners argue that they are operated exclusively for
“charitable” purposes. The term charitable is used in section
501(c)(3) in its generally accepted legal sense, which includes
the “advancement of education” and “lessening the burdens of
Government”. Nationalist Movement v. Commissioner, 102 T.C. 558,
576, affd. 37 F.3d 216 (5th Cir. 1994); Sec. 1.501(c)(3)-1(d)(2),
Income Tax Regs.
A. Advancement of Education
Petitioners contend that they advance education in two ways.
We reject both of petitioners' contentions. First, petitioners
argue that they advance education by assisting the Schools in
meeting several requirements imposed by the ACGME accreditation
standards. Petitioners contend that they assist in the provision
of uniform pay and benefits for residents of similar experience
levels, as required by the accreditation standards. The
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