Wayne Baseball, Inc. - Page 7

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          by the statute.  See Hutchinson Baseball Enters., Inc. v.                   
          Commissioner, supra at 152.  The term "charitable" embraces "'any           
          benevolent or philanthropic objective not prohibited by law or              
          public policy which tends to advance the well-doing and well-               
          being of man.'"  Id. at 153.                                                
               In Hutchinson Baseball Enters., Inc., we held that                     
          promotion, advancement, and sponsorship of amateur baseball are             
          exempt purposes under section 501(c)(3).  See id.  The                      
          organization in Hutchinson Baseball Enters., Inc. sponsored a               
          highly skilled adult amateur baseball team.  It also leased and             
          maintained baseball fields for the use of Little League teams, a            
          local community college team, American Legion teams, and a                  
          baseball camp.  In addition, the organization provided coaches              
          for the Little League teams and baseball camp.  See id. at 147.             
          The Court held that these activities as a whole advanced amateur            
          baseball in the Hutchinson community.  See id. at 155.                      
               In Media Sports League, Inc., the Court addressed a similar            
          issue but concluded that a corporation is not a section 501(c)(3)           
          organization when its activities solely sponsor sports games for            
          novice adult amateur athletes.  We distinguished the organization           
          in Media Sports League, Inc. from the organization in Hutchinson            
          Baseball Enters., Inc. as follows:                                          
                    In Hutchinson we found the organization's                         
               predominant motivation for engaging in its activities                  
               was the furtherance of amateur athletics.  The                         

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