- 14 -
In other words, if an organization can be shown to benefit
private interests, a limitation substantially overlapping but
encompassing more than simply the inurement of earnings to
insiders, it will be deemed to further a nonexempt purpose. Am.
Campaign Acad. v. Commissioner, supra at 1066, 1068-1069; Church
of the Transfiguring Spirit, Inc. v. Commissioner, 76 T.C. 1, 5 &
n.5 (1981). Private benefits within the scope of the prohibition
may include an advantage, profit, fruit, privilege, gain, or
interest. Am. Campaign Acad. v. Commissioner, supra at 1065-
1066.
A substantial body of caselaw has explored the concept of
private benefit within the framework of the relationship between
an organization claiming tax-exempt status and its founder (or
small group of related insiders). See, e.g., Founding Church of
Scientology v. United States, 188 Ct. Cl. 490, 412 F.2d 1197,
1199-1202 (1969); Church of Eternal Life & Liberty, Inc. v.
Commissioner, 86 T.C. 916, 927-928 (1986); Church of the
Transfiguring Spirit, Inc. v. Commissioner, supra at 5-6; Basic
Bible Church v. Commissioner, 74 T.C. 846, 856-858 (1980), affd.
sub nom. Granzow v. Commissioner, 739 F.2d 265 (7th Cir. 1984);
Bubbling Well Church of Universal Love, Inc. v. Commissioner, 74
T.C. 531, 534-538 (1980), affd. 670 F.2d 104 (9th Cir. 1981);
Unitary Mission Church v. Commissioner, 74 T.C. 507, 512-515
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