-4-
(2) If the answer to issue (1) is “yes”, then whether
the retroactive revocation of the favorable ruling letter
was an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulation and
the stipulated exhibits are incorporated herein by this
reference.
When the petition was filed in the instant case, petitioner
was an Ohio not-for-profit corporation, and its principal office
was in Cleveland, Ohio.
The Variety Club charities were founded in 1936 to raise
money for disabled or handicapped children. At the time of the
trial, there were about 80 Variety Club tents (chapters) in the
United States, Australia, France, Israel, Mexico, and
Switzerland.
Petitioner was incorporated in Ohio on December 17, 1970.
Variety Club of Northern Ohio Tent No. 6 (hereinafter sometimes
referred to as the Club) was originally formed in the late 1930’s
in northern Ohio to benefit handicapped and disadvantaged
children. The Club is an Ohio not-for-profit corporation.
Petitioner was organized by the Club for the specific purpose of
raising funds from the general public for various activities
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