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IV. Conclusion
We hold that petitioners have not satisfied their burden of
establishing that respondent's final adverse determinations were
erroneous. Our holding is consistent with the policy underlying
section 501(c)(3). The Supreme Court has stated that Congress,
in enacting section 501(c)(3), sought to “encourage the
development of private institutions that serve a useful public
purpose or supplement or take the place of public institutions of
the same kind.” Bob Jones Univ. v. United States, 461 U.S. 574,
588 (1983). In essence, an organization obtains exemption from
tax under section 501(c)(3) in recognition of its contribution to
the public. Petitioners make no such contribution.
To reflect the foregoing,
Decisions will be entered
for respondent.
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