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not been shown for submission of evidence in addition to the
administrative record, and, therefore, the motion was denied.
What is contained in the administrative record, in terms of
petitioner’s factual foundation, is wholly unpersuasive.
Using as a source an IRS publication, “Cumulative List of
Organizations described in Section 170(c) of the Internal Revenue
Code of 1986", revised to September 30, 1989, petitioner points
out that there are many listed organizations whose names begin
with words of apparent ethnic, racial, or sexual partiality, such
as “Black”, “Hispanic”, “Jewish”, and “Gay”. An important
disparity, according to petitioner, is the conspicuous absence of
“White” organizations.
This issue has already been addressed by this Court in
Nationalist Movement v. Commissioner, 102 T.C. at 594-596, in
which we held that there was no evidence of a constitutional
violation. Petitioner’s arguments are identical to those of the
taxpayer in Nationalist Movement. Therefore, there is no reason
to change the analysis or the result reached in that opinion.
For the reasons stated, we conclude that petitioner is not
operated as a section 501(c)(3) organization. We have considered
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