American Campaign Academy v. Commissioner

P is organized to pursue educational and charitable activities. As its primary activity, P operates a school to train individuals to fill responsible positions in political campaigns. P's training program is an "outgrowth" of similar training programs previously sponsored by the National Republican Congressional Committee. Graduates of P's training program are prepared to function in such strategic campaign positions as communications director, finance director, or campaign manager. Approximately 80 percent of P's graduates participated in at least 98 campaigns of Congressional and Senatorial…