- 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 ofPage: 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