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of education or science; erection or maintenance of
public buildings, monuments, or works; lessening of the
burdens of Government; and promotion of social welfare
by organizations designed to accomplish any of the
above purposes, or (i) to lessen neighborhood tensions;
(ii) to eliminate prejudice and discrimination;
(iii) to defend human and civil rights secured by law;
or (iv) to combat community deterioration and juvenile
delinquency. * * * [Sec. 1.501(c)(3)-1(d)(2), Income
Tax Regs.]
Petitioner argues that its activities, which include job
training and job placement for persons who otherwise would remain
unemployed or underemployed, lessen the burdens of the
unemployment and welfare systems. Petitioner maintains that its
goal of creating a “one-stop-job-center” was envisioned by the
Reemployment Act of 1994, S. 1951, 103d Cong., 2d Sess. (1994),
and, therefore, its application for tax exemption should be
treated differently than other applications for tax exemptions.
Respondent claims that petitioner has not established that it
operates exclusively for charitable purposes as defined in
section 1.501(c)(3)-1(d)(2), Income Tax Regs.
Petitioner cites the comments of the Secretary of Labor
before the Senate Finance Committee for the proposition that the
Government has called on citizens to take action to help reduce
the burdens of the current unemployment system. The Secretary
stated:
The mismatch between the current [unemployment]
system’s structure and the needs it is pressed to serve
burdens federal and state taxpayers, and especially
businesses, with enormous costs. State unemployment
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