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The record is vague and inconsistent concerning the
purported activities of petitioner. Petitioner has produced only
one transcript of a seminar conducted from its website. The home
page of petitioner has links to articles entitled “Constitutional
Protection”, “Educational Outreach”, “Nationalist Ideology”,
“Private Attorney-General”, “Pro-Democracy Methodology”, “Relief
for the Poor”, and “Using the First Amendment as Democracy’s
Shield and Sword”, which petitioner has refused to place in the
administrative record. Also, petitioner has attempted to
countermand and withdraw much of the administrative record, such
that only a skeletal description of its activities would remain
for the Court to examine if we were to allow petitioner to modify
the administrative record. The reasonable inference from the
record is that petitioner does not meet the requirements of
section 501(c)(3).
The few activities of petitioner that have been disclosed
fall outside of the definitions of “charitable” and “educational”
under section 501(c)(3). Section 1.501(c)(3)-1(d)(2), Income Tax
Regs., specifically states that examples of charitable activities
are ones designed “to lessen neighborhood tension” and “to
eliminate prejudice and discrimination.” Petitioner’s actions
serve the purpose of increasing social activism of promajority
and rightist beliefs and are antithetical to these examples.
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Last modified: May 25, 2011