- 6 - On October 6, 1994, petitioner responded to the Commissioner's letter of August 2, 1994. This response was no more informative than the prior responses as to the specifics of petitioner's organization, activities, or operation. The latest response repeated many of the statements set forth on the prior response. On December 13, 1994, the Commissioner issued to petitioner a 30-day letter reflecting the Commissioner's determination that petitioner did not qualify under section 501(c)(3) because it failed the operational test of section 1.501(c)(3)-1(c), Income Tax Regs. On February 2, 1995, petitioner notified the Commissioner that it was appealing that determination, and approximately 6 months after that, Mr. Tully met with one of the Commissioner's Appeals officers to discuss petitioner's case. On or about August 10, 1995, petitioner filed with the Commissioner a second Form 1023. Petitioner's second Form 1023 stated that the primary purpose of the foundation, as stated in its oroginal [sic] application for exemption, * * * [was] amended to read as follows: "The primary purpose of the foundation will be to raise funds for financially strap families living within the immediate area of the foundation's base of operation with all funds being administered by other IRS approved 501(c)(3) charitable organizations such as the Salvation Army, United Way and the Catholic Church". * * * the foundation will limit its currect [sic] fund raising activities to raising funds directly from itsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011