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that the determinations are in error. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Moreover, deductions are a
matter of legislative grace, and the taxpayer must be able to
point to an applicable statute to show that a claimed deduction
comes within its terms. Interstate Transit Lines v.
Commissioner, 319 U.S. 590 (1943).
Section 170(a) allows as a deduction, subject to the
percentage limitations of section 170(b), any charitable
contribution as defined in section 170(c). Section 170(c)
provides, in part, that the term "charitable contribution" means
a contribution to or for the use of "a corporation, trust, or
community chest, fund, or foundation * * * organized and operated
exclusively for religious, charitable, scientific, literary, or
educational purposes * * * no part of the net earnings of which
inures to the benefit of any private shareholder or individual."
Petitioners have not satisfied their burden of establishing
that the Cantare Chorale singers was an organization exempt under
section 501(c), such that contributions thereto would be
deductible under section 170(a).
Section 1.501(c)(3)-1(b)(1), Income Tax Regs., provides
generally that an organization is organized exclusively for one
or more exempt purposes only if the "articles of organization"
(a) limit the purposes of such organization to one or more exempt
purposes, and (b) do not expressly empower the organization to
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