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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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