- 13 -
those debts. The fundraising efforts conducted under the new
contract were not successful, and petitioner suffered a
substantial financial loss on the mailings done, and was unable
to pay all of the fundraising expenses.
On November 2, 1990, respondent issued to petitioner a final
notice of revocation of the favorable ruling letter retroactive
to June 11, 1984. The notice of revocation states, in pertinent
part, as follows:5
We have completed our review of your activities, and
examination of your Forms 990 for the years ending December
31, 1986 and December 31, 1987.
By a determination letter dated March 31, 1969, we
recognized your exemption from Federal Income tax under
section 501(c)(3) * * *.
As a result of the examination of your activities and
financial records for the years noted above, we had
unresolved questions concerning your mailings and your
exempt status. On July 12, 1989, we requested technical
advice from our National Office in order to resolve these
questions.
In response to the request for technical advice, our
National Office ruled that your exemption from income tax
should be revoked effective June 11, 1984.
* * * * * * *
This letter constitutes formal notification of revocation of
your exemption from Federal income tax effective June 11,
1984.
* * * * * * *
5 There are some slight differences between the notice of
revocation letter identified by both sides in the pleadings, and
the one that the parties have stipulated in the administrative
record; these differences appear to be irrelevant to any matter
in dispute. In these findings we have used the letter that is in
the administrative record.
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