The Church of the Living Tree - Page 5

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                    Our primary activity is the cultivation and                       
               planting of trees.  This is ongoing.  Through the                      
               organization of the Church, we hope to accelerate our                  
               planting of trees.                                                     
                    Our main secondary activity is to work towards                    
               establishing an industry of papermaking from                           
               appropriate fiber sources (e.g., kenaf, hemp, rice,                    
               straw, etc.) to relieve trees from the assaults of the                 
               pulp and paper industry for wood chips.                                
                    As a hand paper maker, I experiment with                          
               alternative fibers and am ready to proceed to                          
               papermaking on a larger scale as a pilot project for                   
               the future.                                                            
               Thereafter, a period of correspondence ensued between                  
          respondent and petitioner concerning petitioner's support and               
          activities in which petitioner engaged or proposed to engage.  In           
          1994, in response to inquiries from respondent, petitioner                  
          indicated that it was willing to amend its charter of                       
          organization in certain respects and enclosed a proposed draft of           
          language for such amendment.  Nevertheless, the record does not             
          show that such amendment to petitioner's articles of organization           
          was ever adopted.  In April 1994, respondent notified petitioner            
          that she proposed to rule adversely to petitioner's request for             
          exemption on the grounds, inter alia, that it was not a church.             
          In May 1994, petitioner protested this proposed ruling.                     
               Nevertheless, on January 10, 1995, respondent issued her               
          final adverse ruling letter, denying petitioner's request for               
          exemption under section 501(c)(3).  In denying petitioner's                 
          request for exemption, respondent stated:                                   






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