IHC Health Plans, Inc. - Page 30

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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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