(plaintiff corporation denoted its purpose as agribusiness resource center; predecessor was for-profit consulting business that focused on regulatory compliance; plaintiff claimed that without non-profit status it couldn't partner with trade associations because the couldn't share revenue with for-profit entity; court upheld Tax Court determination that plaintiff not operated exclusively for tax-exempt purposes; plaintiff's operations were commercial rather than charitable and business involved offering fee-based compliance services and plaintiff did not establish that profits would not inure to benefit of private persons or shareholders).