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continually solicit ideas, and select those promising the
greatest benefit to humankind. Interest income from the
growing prizes will be used to fund and promote new prizes
so the corporation can continue creating and awarding prizes
into the indefinite future.
Such generalizations do not satisfy us that petitioner qualifies
for the exemption. See La Verdad v. Commissioner, supra at 221;
World Family Corp. v. Commissioner, supra at 966.
The single activity for which petitioner did provide detail,
raising money to award a prize to a manufacturing company that
develops and builds a reliable car, was determined by respondent
to promote the private interests of for-profit companies as
opposed to public charitable purposes. In addition, respondent
found that the activity would not lessen the burdens of the
Government. Petitioner concedes that its activity will not
lessen the burdens of the Government but contends it will relieve
the poor and distressed by providing transportation less costly
to purchase and maintain.
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Last modified: May 25, 2011