- 4 -
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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