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were permitted to become members while paying reduced premiums.
Aside from the free health screenings mentioned above, petitioner
did not provide or arrange to provide free health care services.
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
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
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