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An organization is not organized or operated exclusively for
one or more of the purposes specified in * * *[section
501(c)(3)] unless it serves a public rather than a private
interest. Thus, * * * it is necessary for an organization
to establish that it is not organized or operated for the
benefit of private interests * * *
Private interests within the meaning of this rule may include not
only related persons and insiders but also unrelated and
disinterested private parties. See Am. Campaign Acad. v.
Commissioner, supra at 1068-1069. If the unrelated and
disinterested third party is a charitable class, bestowing of
benefits on that class will not be grounds for denying the
exemption. See Aid to Artisans, Inc. v. Commissioner, 71 T.C.
202, 208, 212-213 (1978). However, if the disinterested third
party is not a charitable class, benefits bestowed on the third
party, if substantial and not incidental, will be sufficient to
cause the exemption to be denied. See Am. Campaign Acad. v.
Commissioner, supra at 1068; Christian Stewardship Assistance,
Inc. v. Commissioner, 70 T.C. 1037 (1978).
Car and truck manufacturers, who will receive the prize, are
not members of a charitable class. Cf. Aid to Artisans, Inc. v.
Commissioner, supra at 215. After examining the administrative
record, we have no reasonable basis, other than speculation by
petitioner, to conclude that the poor and distressed or any other
charitable class would receive any benefit from the activity
proposed. We conclude that the administrative record fully
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