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organization provided coaching and instruction for
children and recruited only top amateur baseball
players to play on the team it sponsored. The
organization also hired a coach, general manager and
trainer to work with the team. Petitioner, in
contrast, provides no formal or ongoing instruction to
its members, has no skill requirements for eligibility
to play in its leagues and does not require members to
participate in any of its activities. Petitioner also
provides facilities and equipment for its members. An
organization may engage in a particular activity for
exempt and nonexempt purposes, but the operational test
will be satisfied only if the taxpayer is operated
exclusively for one or more of the exempt purposes
specified in the statute. * * * Although we believe
that the furtherance of amateur athletics is one of
petitioner's goals, we find that a substantial purpose
was to further the social and recreational interests of
its members. We have repeatedly held that
organizations whose activities are directed
substantially toward social and recreational purposes
are not eligible for section 501(c)(3) status.
[Media Sports League, Inc. v. Commissioner, supra;
citations omitted.]
We conclude that petitioner is unlike the organization in
Hutchinson Baseball Enters., Inc. and indistinguishable from the
organization in Media Sports League, Inc. In Hutchinson
Baseball Enters., Inc., the activities of the organization
primarily promoted baseball in the surrounding community by
maintaining a baseball field for the public and providing
coaches for Little League teams and baseball camp. Hutchinson
Baseball Enters., Inc. v. Commissioner, supra at 155. In
contrast, the only activity sponsored by petitioner is the
operation of the adult amateur baseball team. As in Media
Sports League, Inc., the primary beneficiaries of petitioner are
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