Michael T. Caracci and Cindy W. Caracci, et al. - Page 60




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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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