- 8 - It is to make sure that the person or persons in question do not have to go hungry over night or not have a safe place to stay. Included in this immediate need might be considered a doctor appointment for life threatening situations. On July 24, 1996, the Commissioner issued to petitioner a final adverse determination letter. The letter stated: Our adverse determination was made for the following reason(s): You did not meet the operational test under section 1.501(c)(3)-1 of the Income Tax Regulations. In order to qualify under Code section 501(c)(3), an organization must be both organized and operated exclusively for one or more purposes specified in that section. You did not describe your proposed activities in sufficient detail as required by section 1.501(c)(3)-1 of the Regulations. Discussion We must decide whether petitioner qualifies for exempt status under section 501(c)(3). We have recently decided the same issue adversely to five other entities also formed and represented by Mr. Tully, in cases with administrative records virtually identical to the administrative record at hand. See Resource Management Found. v. Commissioner, T.C. Memo. 1999-224; Share Network Found. v. Commissioner, T.C. Memo. 1999-216; Tamaki Found. v. Commissioner, T.C. Memo. 1999-166; Tate Family Found. v. Commissioner, T.C. Memo. 1999-165; Larry D. Bowen Family Found. v. Commissioner, T.C. Memo. 1999-149. In each of thosePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011