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          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 15, 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, or                 
               family, under consideration is without "immediate funds                
               in sufficient amount to provide the very necessities of                
               life for the present day, or week, at most".                           
                    It is not to bail out any person or family from                   
               their current financial psoition [sic].  Rather, it is                 
               a temporary means of relief that is intended to assist                 
               that person or family in their immediate need of foods                 
               and or lodging for at least a day or two, perhaps a                    
               week at the most until they can get on relief or find                  
               other assistance, if that be the case.                                 
                    It is to make sure that the person or persons in                  
               question do not have to go hungry over night or not                    
               have a safe place to stay.                                             
                    Included in this immediate need might be                          
               considered a doctor appointment for life threatening                   
               situations.                                                            
               On July 24, 1996, the Commissioner issued to petitioner a              
          final adverse determination letter. The letter stated:                      
               Our adverse determination was made for the following                   
               reason(s):                                                             








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