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Based on the foregoing, petitioner does not satisfy the
organizational test of section 1.501(c)(3)-1(b)(1)(i), Income Tax
Regs., and is not organized exclusively for one or more exempt
purposes as required by section 501(c)(3). Consequently,
petitioner is not entitled to the declaratory judgment it seeks.
We need not address respondent’s contentions that petitioner was
not operated exclusively for exempt purposes, that petitioner’s
net earnings will inure to the benefit of private individuals or
serve private interests, and that petitioner is an action
organization within the meaning of section 1.501(c)(3)-1(c)(3),
Income Tax Regs.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011