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qualified section 501(c)(3) organization exempt from Federal
income tax under section 501(a).
Discussion
A tax exemption is a matter of legislative grace, and an
organization seeking an exemption must prove that it “comes
squarely within the terms of the law conferring the benefit
sought”. Nelson v. Commissioner, 30 T.C. 1151, 1154 (1958); see
also Fla. Hosp. Trust v. Commissioner, 103 T.C. 140, 153 (1994),
affd. 71 F.3d 808 (11th Cir. 1996).
An organization may seek tax-exempt status before it begins
operations, but the administrative record must set forth
sufficient detail about its prospective operations to provide the
basis for the granting of the exemption. Nationalist Movement v.
Commissioner, 102 T.C. 558, 572 (1994), affd. 37 F.3d 216 (5th
Cir. 1994); La Verdad v. Commissioner, 82 T.C. 215, 219 (1984);
World Family Corp. v. Commissioner, 81 T.C. 958 (1983); Church of
Boston v. Commissioner, 71 T.C. 102, 105 (1978); Hancock Acad. v.
Commissioner, 69 T.C. 488, 492 (1977).
Petitioner has, for the most part, provided only
generalizations in response to repeated requests by respondent
for more detail on prospective activities. As petitioner states
in its reply brief:
once momentum for our first prize is substantial, we will
launch additional prizes to benefit of humankind. The
prizes will be chosen only after months and years of
extended deliberation and collaboration. We will
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