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On April 27, 1993, petitioner filed with the Commissioner a
Form 1023, Application for Recognition of Exemption Under Section
501(c)(3) of the Internal Revenue Code (application), in which it
sought recognition as a tax-exempt entity. The application
reported that petitioner's activities were: (1) A school,
college, trade school, etc., (2) other student aid, and (3) job
training, counseling, or assistance. The information that
petitioner provided to the Commissioner on and with the
application was vague as to the specifics of these activities.
The application indicated that petitioner had not currently begun
any activity, except for organizational activities. As to
sources of financial support, the application stated:
At the present time this organization does not have any
procedure for the generation of income other than * * *
* * * * * * *
(a) Direct donations from the general
public at large,
(b) Larger sums from various fund
raising activities,
(c) A possible "Thrift Store" type of
opera-
tion, and
(d) Donations of property (both
personal and real) which can be
turned into cash, and
(e) Various others as may be recommended and
implemented by the organization.
On December 13, 1993, the Commissioner mailed petitioner a
letter seeking clarification of the information that it had
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