Amend16RobertWirengard - Page 18

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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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