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not operated exclusively for an exempt purpose. In the
alternative, respondent determined that, even assuming that
petitioner qualified as an organization described in section
501(c)(3), petitioner was not entitled to tax-exempt status
because a substantial part of its activities consisted of
providing commercial type insurance within the meaning of section
501(m).
On June 16, 1999, respondent also denied Group’s application
for tax-exempt status. On July 21, 1999, respondent issued a
revocation letter to Health Plans revoking its status as an
organization described in section 501(c)(3).
Discussion
Section 501(c)(3)
To qualify as an organization described in section 501(c)(3)
that is exempt from Federal income taxation pursuant to section
501(a), an organization generally must demonstrate: (1) It is
organized and operated exclusively for certain specified exempt
purposes; (2) no part of its net earnings inures to the benefit
of a private shareholder or individual; (3) no part of its
activities constitutes intervention or participation in any
political campaign on behalf of any candidate for public office;
and (4) no substantial part of its activities consists of
political or lobbying activities. See Fla. Hosp. Trust Fund v.
Commissioner, 103 T.C. 140, 145 (1994), affd. 71 F.3d 808 (11th
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