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Better Bus. Bureau v. United States, 326 U.S. 279 (1945). In
Better Bus. Bureau, the Supreme Court stated: “the presence of a
single * * * [nonexempt] purpose, if substantial in nature, will
destroy the exemption regardless of the number or importance of
truly * * * [exempt] purposes”. Better Bus. Bureau v. United
States, supra at 283. Therefore, even if the Court were
satisfied that the Center had an exempt purpose, the existence of
a substantial nonexempt purpose, furthered by the organization’s
activities, would preclude it from qualifying under section
501(c)(3). Church of World Peace, Inc. v. Commissioner, T.C.
Memo. 1994-87.
Petitioner testified extensively about the book publishing
activities of the Center, contending that the publishing and
distribution of literature was a significant aspect of the
Center’s activities. The Center paid for the publishing of such
titles as “Why People Choose the Wrong Mate”, “Beware of the
Spirit of Religion”, and “How to Make the Devil Obey You”.
Petitioner authored each of the books and pamphlets that the
Center published. Although the books had a religious theme,
writing and publishing books is not a religious activity unless
petitioner can prove the primary purpose for publishing the books
was not for profit but for the furtherance of a nonexempt
purpose. The Inc. Trs. of the Gospel Worker Socy. v. United
States, 510 F.Supp. 374 (D.C.D.C. 1981); Pulpit Res. v.
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