South Community Association - Page 20

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          petitioner as a business for profit.  Petitioner does not argue,            
          nor do we find, that this activity was in furtherance of its                
          exempt purpose.7  We therefore conclude that respondent properly            
          revoked petitioner’s tax-exempt status effective January 1, 1992,           
          because petitioner was not operated exclusively for an exempt               
          purpose.  See Help the Children, Inc. v. Commissioner, 28 T.C.              
          1128 (1957); cf. Piety, Inc. v. Commissioner, supra.  While                 
          Congress allows certain organizations tax-exempt status for                 
          specific limited activities, petitioner attempts to retain tax-             
          exempt status for activities that are outside of those permitted.           
               We have considered all arguments made by petitioner for a              
          contrary holding, and we conclude that any of those arguments not           
          discussed herein is without merit.                                          

                                             Decision will be entered for             

               7 Nor does petitioner argue in its posttrial brief that any            
          part of its activities is a “bingo game” as defined in sec.                 
          513(f)(2).  In fact, as to petitioner’s sale of instant pull-tab            
          tickets, the source of most of petitioner’s gaming receipts in              
          each of the years 1992 through 1995, the parties have stipulated            
          that petitioner’s instant pull-tab ticket activity is not a                 
          “bingo game” as defined in sec. 513(f)(2).  See also Julius M.              
          Israel Lodge of B’nai B’rith No. 2113 v. Commissioner, 98 F.3d              
          190 (5th Cir. 1996) (affirming this Court’s determination that              
          instant bingo games are not “bingo games” within the meaning of             
          sec. 513(f)(2)), affg. T.C. Memo. 1995-439.                                 

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