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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 those
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