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rendered as a matter of law. Accordingly, we shall grant
respondent’s Motion For Summary Judgment.
C. Whether Petitioner Is Entitled to Exempt Status
A corporation that is organized and operated exclusively for
charitable purposes, as described in section 501(c)(3), is exempt
from Federal income tax unless exemption is denied under section
502 or 503. Sec. 501(a).
To qualify as an exempt organization under section
501(c)(3), a corporation must satisfy all of the requirements
stated therein, specifically including the requirements that the
corporation must be both organized and operated exclusively for
one or more exempt purposes specified therein and must not
operate for a substantial nonexempt purpose. Exempt purposes
include both charitable and educational purposes. A failure to
satisfy any one of the requirements is fatal to qualification.
Columbia Park & Recreation Association v. Commissioner, 88 T.C.
1, 13 (1987), affd. without published opinion 838 F.2d 465 (4th
Cir. 1988); see sec. 1.501(c)(3)-1(a)(1), Income Tax Regs.
In a declaratory judgment action commenced under section
7428 to review the Commissioner’s denial of an organization’s
application for initial qualification for tax-exempt status under
section 501(c)(3), we ordinarily review only the administrative
record. Rule 217(a); Natl. Association of Am. Churches v.
Commissioner, 82 T.C. 18, 19-20 (1984).
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