- 8 -
similarly are totally unsupported by the record herein. Further,
petitioner acknowledges in its application for section 501(c)(3)
tax-exempt status that petitioner would engage in legislative and
political activities generally not allowed for section 501(c)(3)
organizations. Sec. 1.501(c)(3)-1(c)(3)(i), (ii), and (iii),
Income Tax Regs.
Petitioner argues that, by deciding the issue before us only
on the administrative record, we prevent petitioner from
submitting additional evidence in support of petitioner’s tax-
exempt activities.
Both respondent’s Exempt Organizations Division and
respondent’s Appeals Office informed petitioner of the types of
evidence that might satisfy the requirements of Rev. Proc. 86-43,
supra, and petitioner had more than ample opportunity to submit
whatever evidence it had available. Petitioner instead chose to
submit to respondent more than 1,000 pages of incomprehensible
documents. On the record before us, it is reasonable to hold
petitioner to the administrative record. Petitioner has not
shown good cause for doing otherwise. See Rule 217(a).
We sustain respondent’s denial of petitioner’s request for
tax-exempt status.
Decision will be entered
upholding respondent’s
determination.
Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011