University Medical Resident Services, P.C. - Page 12

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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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