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Petitioner engaged in the exempt activity of raising money
for charitable purposes. Petitioner also operated for the
substantial private benefit of KJ's Place and its owners. A
substantial nonexempt purpose thus characterizes its operation,
disqualifying it from exemption under sections 501(a) and
501(c)(3). Better Business Bureau v. United States, 326 U.S. at
283; Copyright Clearance Center, Inc. v. Commissioner, 79 T.C. at
803.
Decision will be entered
for respondent.
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Last modified: May 25, 2011