Hart Foundation - Page 6




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               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 its                   






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