Oliver Family Foundation - Page 6

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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                   
                    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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