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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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