Oliver Family Foundation - Page 4

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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           
               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           
               "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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