- 18 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011