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On September 20, 1994, the Commissioner mailed petitioner
another letter seeking specificity as to petitioner's
organization, activities, and operation. The letter explained
that the Commissioner needed specific information before he could
rule that petitioner was exempt from taxation under section
501(c)(3). The letter, citing and quoting Rev. Proc. 90-27, sec.
5.02, 1990-1 C.B. 514, 515, stated that
.02 Exempt status will be recognized in advance of
operations if proposed operations can be described in
sufficient detail to permit a conclusion that the
organization will clearly meet the particular
requirements of the section under which exemption is
claimed. A mere restatement of purposes or a statement
that proposed activities will be in furtherance of such
purposes will not satisfy this requirement. The
organization must fully describe the activities in
which it expects to engage, including the standards,
criteria, procedures or other means adopted or planned
for carrying out the activities, the anticipated
sources of receipts, and the nature of contemplated
expenditures. Where the organization cannot
demonstrate to the satisfaction of the Service that its
proposed activities will be exempt, a record of actual
operations may be required before a ruling or
determination letter will be issued. * * *
The letter set forth questions as to specific information that
the Commissioner needed to rule on petitioner's requested
exemption and listed the name and phone number of the person at
the Internal Revenue Service to contact with any questions.
By way of an undated letter to the Commissioner, petitioner
responded to the Commissioner's letter of September 20, 1994.
This response was no more informative than the prior response as
to the specifics of petitioner's organization, activities, or
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