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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 * * *
* * * * * * *
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