Tamaki Foundation - Page 5




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               On September 20, 1994, the Commissioner mailed petitioner              
          another letter seeking specificity as to petitioner's                       
          organization, activities, and operation.  The letter explained              
          that the Commissioner needed specific information before he could           
          rule that petitioner was exempt from taxation under section                 
          501(c)(3).  The letter, citing and quoting Rev. Proc. 90-27, sec.           
          5.02, 1990-1 C.B. 514, 515, stated:                                         
               "Exempt status will be recognized in advance of                        
               operations if proposed operations can be described in                  
               sufficient detail to permit a conclusion that the                      
               organization will clearly meet the particular                          
               requirements of the section under which exemption is                   
               claimed.  A mere restatement of purposes or a statement                
               that proposed activities will be in furtherance of such                
               purposes will not satisfy this requirement.  The                       
               organization must fully describe the activities in                     
               which it expects to engage, including the standards,                   
               criteria, procedures or other means adopted or planned                 
               for carrying out the activities, the anticipated                       
               sources of receipts, and the nature of contemplated                    
               expenditures.  Where the organization cannot                           
               demonstrate to the satisfaction of the Service that its                
               proposed activities will be exempt, a record of actual                 
               operations may be required before a ruling or                          
               determination letter will be issued.  * * *"  [Emphasis                
               added in the letter.]                                                  
          The letter asked for specific information that the Commissioner             
          needed to rule on petitioner's request for exemption and listed             
          the name and phone number of the person at the Internal Revenue             
          Service to contact with any questions.                                      
               By way of an undated letter to the Commissioner, petitioner            
          responded to the Commissioner's letter of September 20, 1994.               
          This response was no more informative than the prior response as            





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