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will or would qualify for an abatement is not yet ripe for
decision, we express no opinion on this issue.
IV. Revocation of Tax-Exempt Status
Section 501(c)(3) requires, among other things, that an
organization be operated exclusively for one or more specified
exempt purposes. An organization is not operated exclusively for
one or more exempt purposes unless it serves a public rather than
a private interest and its net earnings do not inure to the
benefit of any shareholder or individual. Sec. 1.501(c)(3)-1,
Income Tax Regs.
The presence of a single substantial nonexempt purpose can
destroy the exemption regardless of the number or importance of
exempt purposes. Better Bus. Bureau v. United States, 326 U.S.
279, 283 (1945); Am. Campaign Acad. v. Commissioner, 92 T.C.
1053, 1065 (1989). When an organization operates for the benefit
of private interests, such as designated individuals, the creator
or his family, or persons directly or indirectly controlled by
such private interests, the organization by definition does not
operate exclusively for exempt purposes. Prohibited benefits may
include an advantage, profit, fruit, privilege, gain, or
interest. Am. Campaign Acad. v. Commissioner, supra at 1065-
1066. We have held that when a section 501(c)(3) tax-exempt
entity sells its assets for less than fair market value to a for-
profit corporation whose shareholders are directors of the tax-
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