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considered to be a welfare arrangement for employees
and their family, our community; United Affiliations,
is the legal channel that will allow our actual “reach-
out” to involve all community members - from both
private and government sectors, as well as all ranges
of persons or associations within each - and for us to
work together as individuals or groups for common
goals, for example, or for affordable healthcare (a
learning and application process, to the benefit of
everyone); and Circle of Life Ministry, about getting
food, shelter and healthcare for each other (again to
the community’s welfare, and while dealing with the
common notions of conscience or faith based charity).
The letter distinguished petitioner from founder and board member
Robert Wirengard, who “petitioned and lobbied” Federal and State
Government officials and, in December of 2000, presented a
healthcare model to the Health Care Advisory Board of
Hillsborough County.4
In a letter dated October 20, 2003, respondent issued a
final adverse ruling with respect to petitioner’s claim for
exemption. Respondent based the ruling on his determination that
petitioner failed to establish that: (1) Petitioner was organized
exclusively for exempt purposes; (2) petitioner was operated
exclusively for exempt purposes; (3) petitioner’s net earnings
will not inure to the benefit of private individuals or serve
private interests; and (4) petitioner was not an “action”
organization within the meaning of section 1.501(c)(3)-1(c)(3),
Income Tax Regs.
4Robert Wirengard proposed that government pay the costs of
healthcare services for individuals to the extent of the average
costs for such services.
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Last modified: May 25, 2011