Wayne Baseball, Inc. - Page 8

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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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