- 3 - On April 7, 1994, 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) Supplying money, goods or services to the poor, (2) providing services for the aged, and (3) providing aid to the handicapped. The information that petitioner provided to the Commissioner on and with the application was vague as to the specifics of these activities. The application stated generally: The primary objective of the foundation is to be able to offer financial assistance, mostly in the form of actual credit for food or clothing, and/or cash where required, all on a professional approach, to those persons in immediate need. We define those in immediate need as those who are homeless, sick, or under severe financial hardship due to circumstances beyond their control. Further, we define the term immediate need as those who's [sic] need is temporary, as verses [sic] that of a more longer term need. The application indicated that petitioner had not currently begun any activity, except for organizational activities, and that petitioner was not going to begin operating until after the Commissioner recognized it as tax exempt. 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 * * * * * * * * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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