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                    You did not meet the operational test under                       
                    section 1.501(c)(3)-1 of the Income Tax                           
                    Regulations.  In order to qualify under Code                      
                    section 501(c)(3), an organization must be                        
                    both organized and operated exclusively for                       
                    one or more purposes specified in that                            
                    section.  You did not describe your proposed                      
                    activities in sufficient detail as required                       
                    by section 1.501(c)(3)-1 of the Regulations.                      
                                     Discussion                                       
               Respondent has determined that petitioner does not meet the            
          requirements of section 501(c)(3).  Petitioner must prove this              
          determination wrong.  See Rule 217(c)(2)(A); Church By Mail, Inc.           
          v. Commissioner, 765 F.2d 1387, 1391 (9th Cir. 1985), affg. T.C.            
          Memo. 1984-349; Church of Scientology v. Commissioner, 83 T.C.              
          381, 491 (1984), affd. 823 F.2d 1310 (9th Cir. 1987).  In order             
          for petitioner to do so, the administrative record upon which               
          this case is to be decided must contain enough evidence to                  
          support a finding contrary to the grounds set forth in the notice           
          of determination, and petitioner must demonstrate the merits of             
          its claim by at least a preponderance of the evidence.  See                 
          Estate of Gilford v. Commissioner, 88 T.C. 38, 51 (1987); see               
          also Rule 217(c)(2)(A); Fed. R. Evid. 301.  If petitioner fails             
          to carry its burden, respondent will prevail.  See Rockwell v.              
          Commissioner, 512 F.2d 882, 885 (9th Cir. 1975), affg. T.C. Memo.           
          1972-133; American Pipe & Steel Corp. v. Commissioner, 243 F.2d             
          125, 126 (9th Cir. 1957), affg. 25 T.C. 351 (1955); Estate of               
          Gilford v. Commissioner, supra at 51.                                       





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