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* * * [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
review we may draw our own ultimate conclusions and inferences
from the facts. See Am. Campaign Acad. v. Commissioner, supra at
1063-1064; Houston Lawyer Referral Serv., Inc. v. Commissioner,
supra at 573-575.
Section 501(c)(3) specifies various qualifying exempt
purposes, including "charitable" purposes. The term "charitable"
is not defined in section 501(c)(3) but is used in its generally
accepted legal sense. See Nationalist Movement v. Commissioner,
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