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is "TO PROVIDE FINANCIAL ASSISTANCE TO THE NEEDY"; petitioner's
submissions to the Commissioner indicate it intended to provide
this assistance through financial aid grants. The bylaws state
that petitioner's primary purpose is that set forth in the
articles. The bylaws further state that "Nothing herein
contained shall be construed to prevent any Director from
receiving compensation for services to the Corporation rendered
in a capacity other than Director."
On November 4, 1993, 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 indicated that petitioner had not
currently begun any activity, except for organizational
activities. 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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