Salvation Navy, Inc. - Page 9

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          members of a charitable class, or that the fees SNI proposes to             
          charge serve any purpose other than to provide a source of income           
          for Valfer.  Cf. Rev. Rul. 76-244, 1976-1 C.B. 155 (granting                
          exempt status to an organization providing home delivery of meals           
          at cost or less to financially distressed elderly and handicapped           
               Section 501(c)(3) provides for tax-exempt status for                   
          corporations, and any community chest, fund, or foundation,                 
          organized and operated exclusively for, among other things,                 
          charitable purposes.  It does not provide exemption for an                  
          individual engaged in various activities, charitable or                     
          otherwise.  Insofar as can be ascertained from the administrative           
          record, Valfer engaged in various commendable activities--perhaps           
          sometimes in the name of SNI--but the activities were those of              
          Valfer, not SNI.                                                            
               We accordingly conclude that SNI is not operated as a                  
          section 501(c)(3) organization.                                             

                                             Decision will be entered                 
                                        for respondent.                               

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