Peoples Prize - Page 7

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               Section 501(a)1 exempts organizations described in section             
          501(c)(3) from Federal income tax.  In order to qualify for an              
          exemption under section 501(c)(3), the organization must be not             
          only organized exclusively for exempt purposes but also operated            
          exclusively for exempt purposes.  Quality Auditing Co. v.                   
          Commissioner, 114 T.C. 498, 504 (2000).  Respondent conceded that           
          petitioner is organized for exempt purposes but denies that                 
          petitioner will be operated exclusively for exempt purposes.                
               Exempt purposes are broadly stated in section 501(c)(3) to             
          include religious, charitable, scientific, and educational                  




               1 Sec. 501, in relevant part, provides:                                
                  SEC. 501. (a) Exemption From Taxation.— An organization             
               described in subsection (c) * * * shall be exempt from                 
               taxation under this subtitle unless such exemption is denied           
               under section 502 or 503.                                              
                        *    *     *     *     *     *     *                          
                  (c) List of Exempt Organizations.— The following                    
               organizations are referred to in subsection (a):                       
                        *     *     *     *     *     *     *                         
                         (3) Corporations * * * organized and operated                
                  exclusively for * * * charitable * * * purposes, * * *              
                  no part of the net earnings of which inures to the                  
                  benefit of any private shareholder or individual, no                
                  substantial part of the activities of which is carrying             
                  on propaganda, or otherwise attempting, to influence                
                  legislation, * * * and which does not participate in, or            
                  intervene in (including the publishing or distributing              
                  of statements), any political campaign on behalf of (or             
                  in opposition to) any candidate for public office.                  





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