KJ's Fund Raisers, Inc. - Page 6

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            Sec. 1.501(c)(3)-1(d)(1)(ii), Income Tax Regs.  To meet this                              
            requirement, the organization must demonstrate                                            
                  that it is not * * * operated for the benefit of private                            
                  interests such as designated individuals, the creator or his                        
                  family, shareholders of the organization, or persons                                
                  controlled, directly or indirectly, by such private                                 
                  Under the operational test, the organization's purpose,                             
            rather than the nature of its activities, determines whether the                          
            organization is entitled to tax-exempt status.  B.S.W. Group,                             
            Inc. v. Commissioner, 70 T.C. 352, 356-357 (1978).  Even an                               
            organization engaged in only one activity may have multiple                               
            purposes for that activity.  Copyright Clearance Center, Inc. v.                          
            Commissioner, 79 T.C. 793, 803 (1982).  A single nonexempt                                
            purpose, if substantial in nature, will disqualify an                                     
            organization from qualification under section 501(c)(3).  Better                          
            Business Bureau v. United States, 326 U.S. 279, 283 (1945).                               
            Determining the purpose of the organization is a factual question                         
            which concerns "both the actual as well as the stated purposes                            
            for the existence of the organization and the activities it                               
            engages in to accomplish those purposes."  Christian Manner                               
            International, Inc. v. Commissioner, 71 T.C. 661, 668 (1979).                             
                  Petitioner's case is factually similar to P.L.L. Scholarship                        
            Fund v. Commissioner, 82 T.C. 196 (1984).  In that case, the                              
            taxpayer was a nonprofit corporation formed to raise money for                            

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