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Section 501 provides in part:
SEC. 501(a). Exemption From Taxation.--An
organization described in subsection (c) * * * shall be
exempt from taxation under this subtitle unless such
exemption is denied under section 502 or 503.
* * * * * * *
(c) List of Exempt Organizations.--The following
organizations are referred to in subsection (a):
* * * * * * *
(3) Corporations, and any community
chest, fund, or foundation, organized and
operated exclusively for religious,
charitable, scientific, testing for public
safety, literary, or educational purposes,
* * * no part of the net earnings of which
inures to the benefit of any private
shareholder or individual, no substantial
part of the activities of which is carrying
on propaganda, or otherwise attempting, to
influence legislation, * * * and which does
not participate in, or intervene in * * * any
political campaign on behalf of (or in
opposition to) any candidate for public
office.
From this text, we understand that an organization is entitled to
exempt status if it is organized and operated exclusively for
charitable purposes. See also sec. 1.501(c)(3)-1(a)(1), Income
Tax Regs. We also understand that an organization that fails
this test does not qualify for exempt status under section
501(c)(3). See also id.
Respondent focuses entirely on petitioner's failure to
satisfy its burden as to the operational test. So do we.
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