- 5 - status under section 501(c)(3). Respondent concluded that petitioner sought to present to the public only unsupported opinions of Mr. Matthews. On December 19, 2005, petitioner filed with the Court a petition requesting section 7428 declaratory relief as to petitioner’s tax-exempt status under section 501(c)(3). Discussion In reviewing under section 7428 respondent’s denial of an organization’s application for initial qualification for section 501(c)(3) tax-exempt status, we ordinarily review only the administrative record. Rule 217(a); Natl. Association of Am. Churches v. Commissioner, 82 T.C. 18, 19-20 (1984). To qualify for Federal income tax-exempt status under section 501(c)(3) as an educational organization, an organization must, among other things, operate exclusively for educational purposes (operational test). Sec. 1.501(c)(3)-1(a), Income Tax Regs. To meet the operational test, an organization must further educational purposes and not further substantial nonexempt purposes. Nationalist Movement v. Commissioner, 102 T.C. 558, 576 (1994), affd. 37 F.3d 216 (5th Cir. 1994); sec. 1.501(c)(3)- 1(c)(1), Income Tax Regs. Educational purposes include activities that instruct or train individuals to improve or develop their capabilities andPage: Previous 1 2 3 4 5 6 7 8 Next
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