- 8 - 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 arePage: Previous 1 2 3 4 5 6 7 8 9 Next
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