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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
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