University Medical Resident Services, P.C. - Page 19

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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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