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On February 22, 1994, petitioner filed with the Commissioner
a Form 1023, Application for Recognition of Exemption Under
Section 501(c)(3) of the Internal Revenue Code (application), in
which it sought recognition as a tax-exempt entity. The
application reported that petitioner's activities were:
(1) Supplying money, goods, or services to the poor; (2) gifts or
grants to individuals; and (3) services for the aged. The
information that petitioner provided to the Commissioner on and
with the application was vague as to the specifics of these
activities. The application indicated that petitioner had not
currently begun any activity, except for organizational
activities. The application stated, as to sources of financial
support, that
At the present time this organization does not have any
procedure for the generation of income other than * * *
* * * * * * *
(a) Direct donations from the general
public at large,
(b) Larger sums from various fund
raising activities,
(c) A possible "Thrift Store" type of
operation, and
(d) Donations of property (both
personal and real) which can be
turned into cash, and
(e) Various others as may be
recommended and implemented by the
organization.
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