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This case was submitted on the stipulated record pursuant to
Rule 122. The evidentiary facts and representations contained in
the administrative record are assumed to be true. See Rule
217(b)(1).
Background
At the time the petition was filed, petitioner's principal
office was located in Omaha, Nebraska. Petitioner was organized
and incorporated on January 18, 1971, under Nebraska law as a
nonprofit organization primarily to promote athletic education.
On its Form 1023, Application for Recognition of Exemption,
petitioner checked section 509(a)(2) as the reason it was not a
private foundation.
On August 22, 1984, the District Director issued a favorable
determination letter stating that petitioner was an organization
exempt from Federal income taxation under section 501(c)(3). The
letter also stated that petitioner was reasonably expected to be
a publicly supported organization under sections 509(a)(1) and
170(b)(1)(A)(vi). The ruling stated that petitioner would be
treated as a nonprivate foundation during an advance ruling
period ending December 31, 1989.
Petitioner's sole source of support for its 1993, 1994, and
1995 years was income from the sale of pickle cards to liquor
establishments in Nebraska. Pickle cards are a game of chance
authorized by Nebraska statute. See Neb. Rev. Stat. secs. 9-301
through 9-356 (1997 & Supp. 1997). Certain section 501(c)(3),
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