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On June 14, 1994, the Commissioner mailed petitioner a
letter seeking clarification of the information included on and
with the application. The letter specified the information that
the Commissioner needed to rule on petitioner's request for
exempt status and listed the name and phone number of a person at
the Internal Revenue Service to contact with any questions.
On July 11, 1994, William Shelby Oliver responded to the
Commissioner's letter of June 14, 1994. The response gave vague
answers to the questions set forth in the Commissioner's letter
and did not explain in detail petitioner's proposed activities or
operation.
On September 20, 1994, the Commissioner mailed petitioner
another letter seeking specificity as to petitioner's
organization, activities, and operation. The letter, citing and
quoting Rev. Proc. 90-27, sec. 5.02, 1990-1 C.B. 514, 515, stated
that
"Exempt status will be recognized in advance of
operations if proposed operations can be described in
sufficient detail to permit a conclusion that the
organization will clearly meet the particular
requirements of the section under which exemption is
claimed. A mere restatement of purposes or a statement
that proposed activities will be in furtherance of such
purposes will not satisfy this requirement. The
organization must fully describe the activities in
which it expects to engage, including the standards,
criteria, procedures or other means adopted or planned
for carrying out the activities, the anticipated
sources of receipts, and the nature of contemplated
expenditures. Where the organization cannot
demonstrate to the satisfaction of the Service that its
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