On May 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Tikar Inc. v. Commissioner (T.C. Memo. 2021-53). The primary issue presented in Tikar Inc. v. Commissioner was whether Tikar (organized to present exposition of African art owned by a corporation and to promote African art, generally) was operated exclusively for one or more exempt purposes pursuant to IRC § 501(c)(3). The Blessed Rains Down in Africa in Tikar Inc. v. Commissioner In 1993, Dr. Seghers, developed a keen interest in the culture of the Tikar tribe after a short stay in Cameroon, in particular with Tikar artifacts, especially bronze ones.  He imported a number of such artifacts, and others were shipped from Cameroon to Belgium (purportedly) for the good doctor.  Seghers engaged a Cameroonian attorney, but the attorney he chose took a liking to the artifacts and refused to part with them.  In 2005, Seghers “reclaimed”…