- 20 -
will benefit from petitioner’s program. However, these student
programs are an insignificant part of petitioner’s overall
activities.
Rather, petitioner’s activities are primarily structured to
market, determine eligibility for, and enroll individuals in
DMPs. Petitioner plans to inform consumers about the range of
financial services it provides, not about understanding the cause
of, and devising personal solutions to, consumers’ financial
problems. Further, petitioner does not plan to consider the
particular knowledge of individual callers about managing their
personal finances. Instead, petitioner simply plans to collect
data on the callers’ debts as necessary to qualify them for a DMP
or to determine whether they need other services that petitioner
provides.
In short, the record shows that petitioner would not operate
primarily for educational purposes and that educational purposes
were to be a minimal part of petitioner’s proposed activities.
b. Charitable Purposes
Respondent contends that petitioner was not organized
exclusively for charitable purposes. We agree.
The term “charitable” is used in section 501(c)(3) in its
generally accepted sense and includes relief of the poor
and distressed or of the underprivileged. However, primarily
providing services for a fee ordinarily does not further
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: March 27, 2008