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on and with the application. The letter specified the
information that the Commissioner needed to rule on petitioner's
request for exempt status and listed the name and phone number of
a person at the Internal Revenue Service to contact with any
questions.
On September 13, 1993, the Commissioner received a response
to his letter. The response, which was written by Mr. Tully,
gave vague answers to the questions set forth in the
Commissioner's letter and did not explain in detail petitioner's
proposed activities or operation.
On January 20, 1994, the Commissioner mailed petitioner
another letter seeking specificity as to petitioner's
organization, activities, and operation. The letter asked for
specific information that the Commissioner needed to rule on
petitioner's request for exemption and listed the name and phone
number of the person at the Internal Revenue Service to contact
with any questions.
On March 14, 1994, Mr. Tully, on behalf of petitioner,
responded to the Commissioner's letter of January 20, 1994.
This response was no more informative than the prior response as
to the specifics of petitioner's organization, activities, or
operation. Approximately 2 months later, Mr. Hart, in his
capacity as petitioner's president, also responded to the
Commissioner's letter of January 20, 1994. The Commissioner had
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