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non-profit organization be amended, as follows: The
primary purpose of the Oliver Family Foundation shall
be to fund a chair (full professorship) at Overlin
[sic] College, Oberlin, Ohio, in any department that
the college so names.
* * * * * * *
all fund raising carried on by the foundation, in the
future, be raised within the immediate family, their
friends and business associates, and not from members
of the public at large.
The second Form 1023 did not list specifics as to petitioner's
operations, including the manner in which petitioner would effect
its primary purpose. The second Form 1023 did not address any
safeguards against private inurement.
On November 8, 1995, the Commissioner mailed a letter to
petitioner explaining that it had not yet described its
operations in sufficient detail. Three months later, the
Commissioner issued to petitioner a final adverse determination
letter stating:
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.
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Last modified: May 25, 2011