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listing its members, he failed to produce such evidence at
trial.5
Petitioner appeared as a motivational speaker at various
functions throughout Georgia and introduced into evidence several
letters thanking him for his service. In addition, petitioner
sent tape recordings of his “sermons” to several organizations
and also introduced into evidence several letters thanking him
for the tapes. The letters addressed petitioner as “Reverend” or
“Pastor” but made no mention of the church petitioner maintains
he represents. Petitioner failed to substantiate, either to
respondent or to this Court, the relationship of his speaking
ministry to the Center. However, were the Court to assume,
arguendo, that the Center operated for an exempt purpose, the
test is not merely that an organization have an exempt purpose,
but that it must operate “exclusively” for that exempt purpose.
The definition of “exclusively”, under section 501(c)(3)
does not mean solely or absolutely without exception. Church in
Boston v. Commissioner, 71 T.C. 102 (1978). The Supreme Court,
however, has ruled the term has a fairly narrow definition.
5When asked for a membership list, petitioner introduced
into evidence a flier advertising “Mastering Manhood Seminars and
Conferences”. The flier listed 10 men, including petitioner, who
were available to speak for seminars and workshops on various
motivational topics. Petitioner did not testify that the listed
men were members of the Center, nor did he explain why he
considered the flier an accurate membership list; therefore, the
Court declines to give much weight to this evidence.
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Last modified: May 25, 2011