4

Id. at 586. The Court's insistence that tax--exempt organizations provide a “public benefit” is contrary to its opinion in Walz v. Commissioner, 397 U.S. 664 (1970), wherein the Court specifically held that this was not a requirement. In rejecting the university's claim that it automatically was entitled to an exemption without the necessity of a “public policy” analysis because it was organized for educational and religious purposes, the Court observed: “Fagin's school for educating English boys in the art of picking pockets would be an `educational' institution under that definition” and accordingly entitled to tax--exempt status. “Surely,” concluded the Court, “Congress had no thought of affording such an unthinking, wooden meaning to [the federal tax code] as to provide tax benefits to `educational' organizations that do not serve a public, charitable purpose.” Id. at 591 n.18.