Gerald L. and Joy M. Zeidler - Page 8

                                        - 8 -                                         

          engage, otherwise than as an insubstantial part of its                      
          activities, in activities that in themselves are not in                     
          furtherance of one or more exempt purposes.  Section 1.501(c)(3)-           
          1(b)(2), Income Tax Regs., states that "articles of organization"           
          or "articles" includes the trust instrument, the corporate                  
          charter, the articles of association, or any other written                  
          instrument by which an organization is created.                             
               Petitioners presented no organizational documents to                   
          evidence the existence of the Cantare Chorale singers or to                 
          evidence that it was organized for one or more exempt purposes              
          under section 501(c)(3).  Nor was the Court provided with any               
          other admissible documents or evidence that would set out the               
          organization's purposes so as to meet the organizational test.              
          The Court holds that petitioners have not sustained their burden            
          of proving that the organization was exempt for purposes of                 

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011