- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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