At Cost Services, Inc. - Page 7

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               Petitioner bears the burden of proving that it is a section            
          501(c)(3) organization.  See Rule 217(c)(2)(A).  In order for               
          petitioner to meet this burden, the administrative record, upon             
          which this case is to be decided, must contain enough evidence to           
          support a finding contrary to the grounds set forth in the notice           
          of determination.  See Nationalist Movement v. Commissioner, 102            
          T.C. 558, 572 (1994), affd. 37 F.3d 216 (5th Cir. 1994); Church             
          in Boston v. Commissioner, 71 T.C. 102, 105 (1978).  A statute              
          creating an exemption must be strictly construed.  See American             
          Auto. Association v. Commissioner, 19 T.C. 1146, 1158 (1953);               
          Associated Indus. v. Commissioner, 7 T.C. 1449, 1464 (1946).                
               Section 501(a) provides tax-exempt status for organizations            
          described in section 501(c).  Section 501(c)(3) includes the                
          following organizations:                                                    
                    (3) Corporations, and any community chest, fund,                  
               or foundation, organized and operated exclusively for                  
               religious, charitable, scientific, testing for public                  
               safety, literary, or educational purposes, * * * no                    
               part of the net earnings of which inures to the benefit                
               of any private shareholder or individual, no                           
               substantial part of the activities of which is carrying                
               on propaganda, or otherwise attempting, to influence                   
               legislation, * * * and which does not participate in,                  
               or intervene in * * * any political campaign on behalf                 
               of (or in opposition to) any candidate for public                      
          Contributions to organizations described in section 501(c)(3) are           
          generally deductible to donors.  See sec. 170(a)(1), (c)(2).                

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