Resource Management Foundation - Page 4




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          provided him 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 March 10, 1994, the Commissioner received a response to             
          his letter.  The response, which was written by Mr. Tully, 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 August 2, 1994, the Commissioner mailed petitioner                  
          another letter seeking specificity as to petitioner's                       
          organization, activities, and operation.  The letter explained              
          that the Commissioner needed specific information before he could           
          rule that petitioner was exempt from taxation under section                 
          501(c)(3).  The letter, citing and quoting Rev. Proc. 90-27, sec.           
          5.02, 1990-1 C.B. 514, 515, states 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                    





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