That’s STJ Diana L. (“Sidewalks of New York”) Leyden’s direction to Tikar, Inc., 2021 T. C. Memo. 53, filed 5/6/21, as she declares their 501(c)(3) status revoked ab initio.

Tikar, Inc., claimed it was promoting the art of the Cameroons by exhibiting the artifacts of the Tikar people of that country, as well as other African peoples.

Except.

They have serious problems, and STJ Di will tell you all about them.

Tikar neither bought any African artifacts nor exhibited them. They spent money authenticating artifacts owned by a Belgian cardiologist who collected them, but Tikar couldn’t prove he sold or donated them, directly or indirectly, to Tikar. And the artifacts were only exhibited while the Belgian cardiologist still owned them.

“On the basis of administrative record the Court concludes that Tikar was not operated for an exempt purpose because it has not proven (1) that it owned the African artifacts or the [Belgian] Collection and (2) that all of its activities with respect to those artifacts primarily benefit the private interest of Dr. [Belgian] or the [Belgian] Foundation or both. Alternatively, if the Court were to assume that Tikar owned all or any part of the [Belgian] Collection or the African artifacts, Tikar failed to prove that its activities were in furtherance of an exempt purpose, namely charitable or educational.” 2021 T. C. Memo. 52, at p. 33.

A list of exempt purposes is found in Section 501(c)(3).

All the money spent to authenticate the artifacts benefited the owner thereof, and that wasn’t Tikar. So substantial benefit to private parties.

Tikar claims they tried to interest museums in exhibiting the artifacts, but proof is lacking, and they didn’t do anything else.

A charity can do charitable work outside its stated purposes, but it must do them.

Be doers, and not hearers only. That’s STJ Di’s motto.