Peoples Prize - Page 6

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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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