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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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Last modified: May 25, 2011