Hart Foundation - Page 8




                                        - 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 those               






Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011