•Fourth head - the Court reviewed the decision in Native Communications and concluded that the mere dissemination of news was not charitable at law - in part because the organization identified its audience as the general public and not any group or community in need of charitable assistance
•Court held in order to be charitable, the organization’s purposes must be of special benefit to the community, with an eye to society’s current social, moral, and economic context
•The Court did not accept the organization’s argument that presenting the news in an “unbiased and objective” form met this requirement
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