The Nationalist Foundation, A Mississippi Non-Profit Corporation - Page 7




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                  During the administrative proceeding, petitioner attempted                           
            to countermand and withdraw several of its comments, practices,                            
            and activities after the Commissioner determined that these items                          
            would preclude petitioner from qualifying as a section 501(c)(3)                           
            organization.  However, we review the administrative record in                             
            its entirety.                                                                              
                  Section 501(a) provides tax-exempt status for organizations                          
            described in section 501(c).  Section 501(c)(3) includes the                               
            following organizations:                                                                   
                        (c)(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                                    
                  office.                                                                              
            Contributions to organizations described in section 501(c)(3) are                          
            generally deductible to donors.  See sec. 170(a)(1).                                       
                  To come within the terms of section 501(c)(3), an                                    
            organization must be both “organized” and “operated” exclusively                           
            for tax-exempt purposes.  Sec. 1.501(c)(3)-1(a)(1), Income Tax                             
            Regs.  The presence of a single substantial nonexempt purpose                              
            precludes exempt status for the organization, regardless of the                            
            number or importance of exempt purposes.  See Better Bus. Bureau                           






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Last modified: May 25, 2011