The Nationalist Foundation, A Mississippi Non-Profit Corporation - Page 8




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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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