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purpose is that set forth in the articles. The bylaws further
state that "Nothing herein contained shall be construed to
prevent any Director from receiving compensation for services to
the Corporation rendered in a capacity other than Director."
On November 4, 1993, petitioner filed with the Commissioner
a Form 1023, Application for Recognition of Exemption Under
Section 501(c)(3) of the Internal Revenue Code (application), in
which it sought recognition as a tax-exempt entity. The
application reported that petitioner's activities were: (1) A
church, synagogue, etc., (2) an association or convention of
churches, and (3) missionary activities. The information that
petitioner provided to the Commissioner on and with the
application was vague as to the specifics of these activities.
The application indicated that petitioner had not currently begun
any activity, except for organizational activities. As to
sources of financial support, the application stated:
At the present time this organization does not have any
procedure for the generation of income other than * * *
* * * * * * *
(a) Direct donations from the general
public at large,
(b) Larger sums from various fund
raising activities,
(c) A possible "thrift store" type
operation, and
(d) Donations of property (both
personal and real) which can be
turned into cash, and
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