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Commissioner, 69 T.C. 570, 571 (1978).
It is well established that the scope of our inquiry is
limited to the propriety of the reasons given by the Commissioner
for denying an organization's application for exemption. See Aid
to Artisans, Inc. v. Commissioner, 71 T.C. 202, 208 (1978).
Thus, in making our declaration, we do not engage in a de novo
review of the administrative record. See Am. Campaign Acad. v.
Commissioner, supra at 1063; Church in Boston v. Commissioner, 71
T.C. 102, 105-106 (1978); Houston Lawyer Referral Serv., Inc. v.
Commissioner, supra at 573-574, 577. The burden of proof is on
the organization to overcome the grounds for denial of the
exemption set forth in the Commissioner’s determination. See
Rule 217(c)(4)(A); Fla. Hosp. Trust Fund v. Commissioner, supra
at 146; Christian Manner Intl., Inc. v. Commissioner, 71 T.C.
661, 664-665 (1979); Hancock Acad. of Savannah, Inc. v.
Commissioner, 69 T.C. 488, 492 (1977).
The parties do not dispute that petitioner was organized for
an tax-exempt purpose within the meaning of section 501(c)(3).
The dispute in this case centers on whether petitioner was
operated exclusively for an tax-exempt purpose.
Section 1.501(c)(3)-1(c)(1), Income Tax Regs., provides:
(c) Operational test--(1) Primary activities. An
organization will be regarded as "operated exclusively"
for one or more exempt purposes only if it engages
primarily in activities which accomplish one or more of
such exempt purposes specified in section 501(c)(3).
An organization will not be so regarded if more than an
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