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it likewise is well settled that the organization bears the
burden of overcoming the grounds set forth in the Commissioner’s
final ruling letter. See, e.g., Am. Campaign Acad. v.
Commissioner, supra at 1063-1064; Basic Bible Church v.
Commissioner, 74 T.C. at 856.
Because an exemption is a deviation from the norm of
taxation, courts have reasoned that “a heavy burden” to establish
satisfaction of all requisites for such status falls on the
entity. Harding Hosp., Inc. v. United States, 505 F.2d 1068,
1071 (6th Cir. 1974). In the words of the Court of Appeals for
the Fifth Circuit, to which appeal in the instant case would
normally lie: “It is the burden of the party claiming the
exemption, of course, to prove entitlement to it.” Senior
Citizens Stores, Inc. v. United States, 602 F.2d 711, 713 (5th
Cir. 1979).
There exist, however, several exceptions to the general
rule. Section 7491(a)(1) may shift the burden to the
Commissioner with respect to factual issues where the taxpayer
introduces credible evidence, but the provision operates only
where the taxpayer establishes that he or she has complied under
section 7491(a)(2) with all substantiation requirements, has
maintained all required records, and has cooperated with
reasonable requests for witnesses, information, documents,
meetings, and interviews. See H. Conf. Rept. 105-599, at 239-240
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