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Contributions to you are no longer deductible as provided in
section 170 * * * .
On November 2, 1990, respondent also issued a notice of
deficiency to petitioner, determining income tax deficiencies for
1986 and 1987.
On January 30, 1991, after the bankruptcy court lifted the
automatic stay, petitioner filed its petition initiating the
instant declaratory judgment action pursuant to section 7428. On
January 30, 1991, petitioner also filed its petition initiating a
proceeding for review of the notice of deficiency issued to it
for 1986 and 1987, United Cancer Council, Inc. v. Commissioner,
docket No. 2009-91. The parties have agreed that the deficiency
proceeding should be held in abeyance pending the resolution of
the instant declaratory judgment action.
Direct Mail Fundraising
W&H operated with the understanding that direct mail
solicitation allows an organization’s marketing and solicitation
efforts to directly focus on and target specific individuals. In
W&H’s view, in comparison to direct mail solicitation,
solicitations conducted through the print media or radio will
generally reach a nonspecific and less targeted audience. W&H’s
advice to petitioner and actions under the Contract were based in
part on these understandings.
In a direct mail fundraising campaign, a “prospect letter”
is a letter mailed to an individual who has not previously
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