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operated as a section 501(c)(3) organization. The operational
test requires the activities of an organization to be primarily
those that accomplish an exempt purpose as described in section
501(c)(3). See sec. 1.501(c)(3)-1(c)(1), Income Tax Regs. A
single substantial nonexempt purpose will disqualify an
organization despite the importance of its exempt purpose. See
Better Business Bureau v. United States, 326 U.S. 279, 283
(1945). If an organization serves private rather than public
interests, it also will not meet the operational test. See sec.
1.501(c)(3)-1(d)(1)(ii), Income Tax Regs.
Petitioner contends that it operates exclusively for one or
more exempt purposes within the meaning of section 501(c)(3) and
does not further private interests. In support of this
assertion, petitioner relies on Hutchinson Baseball Enters., Inc.
v. Commissioner, supra at 155-156, which held that the promotion
of amateur baseball is an exempt purpose. Respondent argues that
petitioner does not qualify under section 501(c)(3) because more
than an insubstantial part of the activities of petitioner
furthers nonexempt social and recreational interests of its
members. Respondent relies on the similarities of this case to
Media Sports League, Inc. v. Commissioner, T.C. Memo. 1986-568,
which denied exempt status to an amateur sports league.
Section 501(c)(3) exempt purposes are those of a charitable
character and are not limited to the classifications enumerated
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