- 18 - 1. Whether Petitioner Is Organized Exclusively for Exempt Purposes Whether an organization is organized exclusively for exempt purposes is sometimes known as the organizational test. To satisfy the organizational test, the articles of organization (1) must limit the organization’s purposes to one or more exempt purposes; (2) may not expressly authorize the organization to engage in activities that do not further one or more exempt purposes except to an insubstantial degree; and (3) must contain an express or implied provision dedicating its assets to an exempt purpose upon dissolution. Sec. 1.501(c)(3)-1(b)(1) through (4), Income Tax Regs. a. Educational Purposes Petitioner contends that it satisfies the organizational test because it was organized for educational purposes and that use of DMPs was only a minimal part of its revenue. However, the administrative record clearly demonstrates otherwise. Petitioner’s articles of incorporation do not limit its activities to those related to education because the articles empower petitioner to engage in activities that are not purely charitable or educational. For example, petitioner could operate an investment business and offer products and services with respect to a customer’s individual needs. Those activities stand in stark contrast to educational purposes acceptable under section 501(c)(3), which include activities that instruct orPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: March 27, 2008