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v. Commissioner, 103 T.C. 140, 145 (1994), affd. 71 F.3d 808
(11th Cir. 1996); Am. Campaign Acad. v. Commissioner, 92 T.C.
1053, 1062 (1989); IHC Health Plans, Inc. v. Commissioner, T.C.
Memo. 2001-246, affd. 325 F.3d 1188 (10th Cir. 2003). Section
501(c)(3) provides for the following exempt purposes: Religious,
charitable, scientific, testing for public safety, literary,
educational, and prevention of cruelty to children or animals.
Sec. 1.501(c)(3)-1(d)(1)(i), Income Tax Regs.
It is well established that our inquiry focuses on the
reasons given by the Commissioner for denying an organization’s
application for exemption. See Aid to Artisans, Inc. v.
Commissioner, 71 T.C. 202, 208 (1978). Thus, in making our
declaration, we do not engage in a de novo review of the
administrative record. See Am. Campaign Acad. v. Commissioner,
supra at 1063; Church in Boston v. Commissioner, 71 T.C. 102,
105-106 (1978); Houston Lawyer Referral Serv., Inc. v.
Commissioner, 69 T.C. 570, 573-574, 577 (1978).
The first of the section 501(c)(3) requirements mandates
that an organization be organized exclusively for one or more of
the exempt purposes. The exempt purposes requirement is met only
if the organization satisfies the organizational as well as the
6(...continued)
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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