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Commissioner, 75 T.C. 337, 343 (1980); Aid to Artisans, Inc. v.
Commissioner, 71 T.C. 202, 210-211 (1978). To determine whether
the operational test has been satisfied, we look beyond “the four
corners of the organization’s charter to discover 'the actual
objects motivating the organization'”. American Campaign Academy
v. Commissioner, supra at 1064.
Although an organization might be engaged in only a single
activity, that single activity might be directed toward multiple
purposes, both exempt and nonexempt. If the nonexempt purpose is
substantial in nature, the organization will not satisfy the
operational test. See KJ’s Fund Raisers, Inc. v. Commissioner,
166 F.3d 1200 (2d Cir. 1998), affg. without published opinion
T.C. Memo. 1997-424; Manning Association v. Commissioner, 93 T.C.
596, 603-605 (1989); American Campaign Academy v. Commissioner,
supra at 1065; Copyright Clearance Ctr., Inc. v. Commissioner, 79
T.C. 793, 804 (1982). “The presence of a single * * * [non-
exempt] purpose, if substantial in nature, will destroy the
exemption regardless of the number or importance of truly * * *
[exempt] purposes.” Better Bus. Bureau, Inc. v. United States,
326 U.S. 279, 283 (1945).
The fact that an organization engages in a trade or business
is not conclusive of a substantial nonexempt purpose and does
not, in and of itself, disqualify the organization from exemption
under section 501(c)(3), provided the activity furthers or
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