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On October 29, 1998, respondent issued a final adverse
determination letter to petitioner denying its application for
tax-exempt status pursuant to section 501(c)(4). The record does
not reflect the date that petitioner filed its application for
exemption under section 501(c)(4) or whether petitioner filed a
petition for declaratory judgment with the Court challenging that
determination.
On June 16, 1999, respondent issued a final adverse
determination letter to petitioner denying its application for
tax-exempt status pursuant to section 501(c)(3). On June 16,
1999, respondent also denied Care’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;
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