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2. Whether Petitioner Is Operated Exclusively for
Charitable Purposes
We focus now on petitioner’s operations to decide whether
petitioner satisfies the operational test. Petitioner has not
begun to actually operate. However, its plans make clear: (a)
Petitioner’s primary activity would be to provide DMPs to the
general public for a fee that it hopes to collect from its
customers and from its customers’ creditors; (b) petitioner would
conduct this activity in a self-promotional and profit-maximizing
manner; (c) petitioner would not limit its DMP services to low-
income individuals; and (d) petitioner has not established that
its proposed DMP fee structure is reasonable. Thus, the
administrative record establishes that petitioner does not, or,
more accurately, would not, operate exclusively for charitable
purposes.
2(...continued)
personal money management and aiding low-income persons with
financial problems by providing free counseling and, if
necessary, establishing a budget plan for the orderly discharge
of indebtedness, was considered to have furthered charitable
purposes. Id. In contrast, the Commissioner has indicated that an
organization assisting persons with financial problems by
analyzing their specific problems, counseling them on the payment
of their debts, and setting up payment plans based on their
ability to pay was not exempt under sec. 501(c)(3), because the
organization was not engaged in educational activities and did
not limit its program to persons who were in need of such
assistance as proper recipients of charity. Id.; Rev. Rul. 65-
299, 1965-2 C.B. 165.
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