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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
respondent.
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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