The Tax Court has denied a 501(c)(3) charitable exemption to a California nonprofit corporation formed to advocate and litigate for the legal rights of federal student loan recipients. In response to a declaratory judgment suit by the organization, the Court has agreed with the IRS that the organization did not prove it would operate primarily for a charitable purpose and not to promote the private interests of its founder. The Council for Education was founded in 2006 by Harold Huggins, a former student at the University of California at Santa Barbara, who served as president, secretary and sole officer, director and employee. Huggins had a history of filing administrative complaints and...