- 6 - the primary purpose of the foundation, as stated in its oroginal [sic] application for exemption, * * * [was] amended to read as follows: "The primary purpose of the foundation will be to raise funds for financially strap families living within the immediate area of the foundation's base of operation with all funds being administered by other IRS approved 501(c)(3) charitable organizations such as the Salvation Army, United Way and the Catholic Church". * * * the foundation will limit its currect [sic] fund raising activities to raising funds directly from its officers, directors and their immediate familites [sic], friends and business associates. 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 April 9, 1996, the Commissioner mailed a letter to petitioner explaining that it had not yet described its operations in sufficient detail. The letter set forth four items of information that the Commissioner lacked as to petitioner, including a definition of the term "financially strap" as set forth in the second Form 1023. By way of an undated letter, Mr. Tully responded to the Commissioner's letter of April 9, 1996. The response was generally vague as to the information sought. As to the definition of the term "financially strap", the letter stated: This organization defines the term "financially strap" as a temporary condition wherein the person, orPage: Previous 1 2 3 4 5 6 7 8 Next
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