Tate Family Foundation - Page 3




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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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Last modified: May 25, 2011