Amend16RobertWirengard - Page 15

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          an insubstantial part of its activities) activities not in                  
          furtherance of one or more exempt purposes.  Sec. 1.501(c)(3)-              
          1(b)(1)(iii), Income Tax Regs.                                              
               In the instant case, the enumerated activities set forth in            
          Article III of the Articles are broad in scope and vague in                 
          description.7  For instance, the Articles empower petitioner to             
          provide economic solutions to identified socioeconomic problems.            
          Such activities do not necessarily further an educational or                
          charitable purpose regardless of the fact that the Articles state           
          that petitioner is organized “exclusively for educational,                  
          welfare and charitable purposes.”  See id.  This Court has held,            
          however, that the mere existence of power to engage in activities           
          other than those set out in section 501(c)(3) does not in itself            
          prevent an organization from meeting the organizational test.               
          Peoples Translation Serv./Newsfront Intl. v. Commissioner, 72               
          T.C. 42, 48 (1979).  A determination of whether an organization             
          is organized exclusively for exempt purposes is based on an                 
          examination not only of the articles of organization but also of            
          other evidence in the administrative record.  See Peoples                   
          Translation Ser./Newsfront Intl. v. Commissioner, supra; Gen.               

               7The enumerated activities include providing “education and            
          advocacy, principally, of the economic and financial sciences”;             
          providing healthcare and transportation; testing “welfare,                  
          healthcare and environmental models”; providing economic                    
          solutions to identified “socio-economic and sustainability”                 
          problems; assisting and organizing employees; and organizing                
          economic welfare arrangements.                                              





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