Hart Foundation - Page 3




                                        - 3 -                                          

               On May 24, 1993, 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) services for the aged, and               
          (3) 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              
          indicated that petitioner had not currently begun any activity,              
          except for organizational activities.  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 * * *                 
                           *    *    *    *    *    *    *                             
                    (a) Direct donations from the general                              
                         public at large,                                              
                    (b) Larger sums from various fund                                  
                         raising activities,                                           
                    (c) A possible "Thrift Store" type of                              
                         operation, and                                                
                    (d) Donations of property (both                                    
                         personal and real) which can be                               
                         turned into cash, and                                         
                    (e) Various others as may be                                       
                         recommended and implemented by the                            
                         organization.                                                 
               On July 9, 1993, the Commissioner mailed petitioner a letter            
          seeking clarification of the information that it had provided him            



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