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The documents that petitioner presents to the public through
Mr. Matthews are full of unsupported opinions and distorted
facts. Petitioner’s presentations and documents use inflammatory
language and emotional and irrelevant statements. Factors one,
two, three, and four of Rev. Proc. 86-43, supra, clearly apply to
the activities of petitioner.
Because petitioner’s activities appear principally to
involve the presentation to the public of unsupported opinions,
petitioner’s activities do not further educational purposes under
the operational test. On the record before us, petitioner does
not qualify for tax-exempt status under section 501(c)(3) as an
educational organization.
Even apart from the criteria of Rev. Proc. 86-43, supra,
petitioner’s activities do not qualify as educational under the
generally accepted use of that term. See Natl. Alliance v.
United States, 710 F.2d 868, 873, 875 (D.C. Cir. 1983).
Petitioner’s vague claims for qualification as a section
501(c)(3) tax-exempt organization on the grounds that it operates
for charity and for the prevention of cruelty to children
4(...continued)
respondent set forth the factors that respondent had utilized in
Natl. Alliance. See Chief Counsel Advice 200620001 (May 9,
2006).
The Tax Court has held that Rev. Proc. 86-43, supra, is
constitutional. Nationalist Movement v. Commissioner, 102 T.C.
558, 588-589 (1994), affd. on other grounds 37 F.3d 216, 218 (5th
Cir. 1994).
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