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v. United States, 326 U.S. 279, 283 (1945). The actual purposes
of the organization, not necessarily limited to those purposes
stated in the organizing documents, are the appropriate focus.
See American Campaign Academy v. Commissioner, 92 T.C. 1053, 1064
(1989).
As stated in the regulations, the “operational test” is as
follows:
An organization will be regarded as “operated
exclusively” for one or more exempt purposes only if it
engages primarily in activities which accomplish one or
more of such exempt purposes specified in section
501(c)(3). An organization will not be so regarded if
more than an insubstantial part of its activities is
not in furtherance of an exempt purpose. [Sec.
1.501(c)(3)-1(c)(1), Income Tax Regs.]
Of the exempt purposes listed in section 501(c)(3), petitioner
maintains that it operates for charitable and educational
purposes.
The term “charitable” is used in section 501(c)(3) in its
generally accepted legal sense and includes, but is not limited
to:
Relief of the poor and distressed or of the
underprivileged; advancement of religion; advancement
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.]
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