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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 exempt purpose within the meaning of section 501(c)(3). The
dispute in this case centers on whether petitioner was operated
exclusively for an 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
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
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