KJ's Fund Raisers, Inc. - Page 2

                                                - 2 -                                                 

            that it is not exempt from income tax under section 501(a).                               
            Specifically, the Commissioner determined that petitioner failed                          
            to establish that it operated exclusively for exempt purposes                             
            under section 501(c)(3).  This case is before us on a petition                            
            for declaratory judgment pursuant to section 7428.  The parties                           
            filed a joint stipulation as to the completeness and correctness                          
            of the administrative record and submitted this case for                                  
            determination under Rule 122.                                                             
                  Kristine Hurd and James Gould are the sole owners of KJ's                           
            Place, a lounge where alcoholic beverages are served.  The term                           
            KJ is obviously derived from the first initials of the first                              
            names of the owners, Kristine and James.  In 1992, Kristine and                           
            James created petitioner, KJ's Fund Raisers, Inc.  They had                               
            petitioner incorporated as a Vermont Non-Profit Corporation on                            
            October 12, 1992.  They also had petitioner file a Form 1023,                             
            Application for Recognition of Exemption Under Section 501(c)(3)                          
            of the Internal Revenue Code on November 11, 1992.                                        
                  Petitioner's business is selling Lucky 7 or other break-open                        
            (or lottery or rip) tickets.  The lottery tickets are sold                                
            exclusively at KJ's Place; no other locations were considered.                            
            The tickets are sold during regular business hours by the owners                          
            and employees of KJ's Place.                                                              
                  Petitioner was organized purportedly to "raise funds for                            
            distribution to charitable causes".  Petitioner expects the                               

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011