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insubstantial part of its activities is not in
furtherance of an exempt purpose.
The operational test focuses on the actual purposes the
organization advances by means of its activities, rather than on
the organization's statement of purpose or the nature of its
activities. See Am. Campaign Acad. v. Commissioner, supra at
1064; Aid to Artisans, Inc. v. Commissioner, supra at 210-211.
Although an organization might be engaged in only a single
activity, that single activity might be directed toward multiple
purposes, both exempt and nonexempt. See Redlands Surgical
Servs. v. Commissioner, 113 T.C. 47, 72 (1999), affd. per curiam
242 F.3d 904 (9th Cir. 2001). "[T]he presence of a single
* * * [non-exempt] purpose, if substantial in nature, will
destroy the exemption regardless of the number or importance of
truly * * * [exempt] purposes." Better Bus. Bureau, Inc. v.
United States, 326 U.S. 279, 283 (1945); see Manning Association
v. Commissioner, 93 T.C. 596, 603-605 (1989); Am. Campaign Acad.
v. Commissioner, supra at 1065.
Whether an organization operates for a substantial nonexempt
purpose is a question of fact to be resolved on the basis of all
the evidence presented in the administrative record. See Church
By Mail, Inc. v. Commissioner, 765 F.2d 1387, 1390 (9th Cir.
1985), affg. T.C. Memo. 1984-349. For purposes of the instant
proceeding, we assume that the facts as represented in the
administrative record are true, although in the course of our
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