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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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