PER CURIAM.
DECISION
The decision of the United States Claims Court, sustaining the Internal Revenue Services' (IRS's) determination that appellant does not qualify as a tax exempt organization under 26 U.S.C. §§ 501(c)(3) and 501(a) (Easter House v. United States, 12 CI. Ct. 476 (1987)), is affirmed.
OPINION
Appellant Easter House is an adoption agency which sought from IRS a declaration of tax exemption as a charitable organization. When this was denied, appellant brought this part-time work. He also was a compensated officer of Friends of Children, Inc. (Friends), an adoption agency comparable to appellant, as well as having "other sources of income." He likewise owned or controlled the Tzyril Foundation and Suko Corporation, both concerned with adoption of foreign children. In 1982-83 appellant Easter House made loans to Friends, Tzyril and Suko. There is no indication in the record of the purposes of these loans, but it is clear that Easter House was used by Kurtz as a source of credit to these entities he controlled. The sum of the evidence is, therefore, that it cannot be said that "no part of the net earnings" (emphasis added) of Easter House inures to the benefit of a private shareholder or individual.