Similarly, although all of the beneficiaries of petitioner's purposes are elderly individuals, aid to pensioners without regard to need, has been held not a charitable purpose. Watson v. United States, 355 F.2d 269 (3d Cir. 1965); Estate of Leeds v. Commissioner, 54 T.C. 781, 790-791 (1970). Petitioner maintains that its legal action has enormous precedential value for the millions of retirees of public pension systems and, therefore, rises to the level of providing public benefit.
The provision of additional compensation or benefits for employment services is not an exempt purpose. See Duffy v. Birmingham, 190 F.2d 738, 740-741 (8th Cir. 1951); cf. Watson v. United States, 355 F. 2d 269, 274 (3d Cir. 1965) (Smith, J., concurring); Estate of Leeds v. Commissioner, 54 T.C. 781, 791 (1970). Thus, if petitioner's principal purpose is to provide compensation for employment services rendered to petitioner's contributors, petitioner is not operated exclusively for any of the exempt purposes described in section 501(c)(3) and is therefore not an exempt organization.