- 12 - 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. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011