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to prevent any Director from receiving compensation for services
to the Corporation rendered in a capacity other than Director."
On April 12, 1994, petitioner filed with the Commissioner a
Form 1023, Application for Recognition of Exemption Under Section
501(c)(3) of the Internal Revenue Code (Application), in which it
sought recognition as a tax-exempt entity. The Application
reported that petitioner's activities were: (1) Supplying money,
goods or services to the poor, (2) providing services for the
aged, and (3) providing aid to the handicapped. The information
that petitioner provided to the Commissioner on and with the
Application was vague as to the specifics of these activities.
The Application stated generally that
The primary objective of the foundation is to offer
financial assistance, mostly in the form of actual cash
and credit, on a professional basis and approach, to
those people who are in immediate need, such as the
homeless, the sick, and any other person whose needs
are temporary in nature, as verses [sic] those who are
in actual need of longterm financial assistance.
The Application indicated that petitioner had not currently begun
any activity, except for organizational activities, and that
petitioner was not going to begin operating until after the
Commissioner recognized it as tax exempt. As to sources of
financial support, the Application stated,
At the present time this organization does not have any
procedure for the generation of income other than * * *
* * * * * * *
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