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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
Cir. 1996); Am. Campaign Acad. v. Commissioner, 92 T.C. 1053,
1062 (1989).
Qualification as an organization described in section
501(c)(3) not only provides an exemption from Federal income
taxes, but also generally permits the organization to solicit and
accept donations which normally are deductible by the donor
against his or her Federal taxes. See sec. 170(c); Bob Jones
Univ. v. United States, 461 U.S. 574, 577-578 (1983). With a few
minor differences, the organizations and requirements listed in
section 170(c)(2) are virtually identical to those described in
section 501(c)(3). With limited exceptions not here relevant,
organizations described in the other paragraphs of section 501(c)
are not eligible to receive tax-deductible contributions.
In the event the Commissioner determines that an
organization does not qualify for tax-exempt status, the
organization may (after exhausting its administrative remedies)
seek judicial review of the matter. Section 7428(a) confers
jurisdiction on the Tax Court, among other courts, to make a
declaration with respect to the initial or continuing
qualification of an organization as an organization described in
section 501(c)(3). See Houston Lawyer Referral Serv., Inc. v.
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