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charitable purposes. See I.H.C. Health Plans, Inc. v.
Commissioner, 325 F.3d l188, 1201 (10th Cir. 2003) (“Offering
products and services to a broad segment of the population is as
consistent with self promotion and profit maximization as it is
with any ‘charitable’ purpose”), affg. T.C. Memos. 2001-246,
2001-247, and 2001-248; Am. Campaign Acad. v. Commissioner, supra
at 1076-1077 (beneficiaries must possess “charitable
characteristics”); Aid to Artisans, Inc. v. Commissioner, 71 T.C.
202, 215-216 (1978) (disadvantaged artisans constitute a
charitable class). A charitable organization’s programs must
also benefit the members of a recognized charitable class in a
“nonselect manner”. See Am. Campaign Acad. v. Commissioner,
supra at 1077; Aid to Artisans, Inc. v. Commissioner, supra at
215-216; sec. 1.501(c)(3)-1(d)(1)(ii), Income Tax Regs. (must
serve public rather than private interests). In short,
petitioner’s potential customers are not members of a class that
is benefited in a “nonselect manner”; indeed, petitioner’s
potential customers are likely to be treated in a “select”
manner, because they will be turned away unless they meet the
criteria of the participating creditors.2
2 We note that in Rev. Rul. 69-441, 1969-2 C.B. 115, the
Commissioner indicated that individuals with financial problems
are not on that account necessarily in need of assistance as
“proper recipients of charity”. We note further that the
Commissioner has ruled that an organization formed to help reduce
the incidence of personal bankruptcy by informing the public on
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