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(a) Direct donations from the general
public at large,
(b) Larger sums from various fund
raising activities,
(c) A possible "thrift store" type
operation, and
(d) Donations of property (both
personal and real) which can be
turned into cash, and
(e) Various others as may be
recommended and implemented by the
organization.
On January 20, 1994, the Commissioner mailed petitioner a
letter seeking clarification of the information that it had
provided him on and with the application. The letter specified
the information that the Commissioner needed to rule on
petitioner's request for exempt status and listed the name and
phone number of a person at the Internal Revenue Service to
contact with any questions. The letter stated: "We can only
recognize you as exempt in advance of operations if you are able
to describe your proposed operations in sufficient detail to
enable us to determine that you will be organized and operated in
accordance with section 501(c)(3) of the Code."
On April 7, 1994, the Commissioner received a response to
his letter. The response, which was written by Mr. Tully in his
capacity as petitioner's vice president, gave vague answers to
the questions set forth in the Commissioner's letter and did not
explain in detail petitioner's proposed activities or operation.
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