At Cost Services, Inc. - Page 9

                                        - 9 -                                         

               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              
               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                   

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011