Tate Family Foundation - Page 6




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          the specifics of petitioner's organization, activities, or                  
          operation.  The latest response repeated many of the statements             
          set forth on the prior response.                                            
               On December 13, 1994, the Commissioner issued to petitioner            
          a 30-day letter reflecting the Commissioner's determination that            
          petitioner did not qualify under section 501(c)(3) because it               
          failed the operational test of section 1.501(c)(3)-1(c), Income             
          Tax Regs.  Approximately 1 month later, Mr. Tully, in his                   
          capacity as petitioner's vice president, notified the                       
          Commissioner that petitioner was appealing that determination,              
          and approximately 6 months after that, Mr. Tully met with one of            
          the Commissioner's Appeals officers to discuss petitioner's case.           
          Shortly after this meeting, petitioner filed with the                       
          Commissioner an amended Form 1023.  As amended, petitioner's Form           
          1023 stated that                                                            
               the primary purpose of the foundation, as stated in its                
               oroginal [sic] application for exemption, * * * [was]                  
               amended to read as follows:                                            
                    "The primary purpose of the foundation will be to                 
               raise funds for financially strap families living                      
               within the immediate area of the foundation's base of                  
               operation with all funds being administered by other                   
               IRS approved 501(c)(3) charitable organizations such as                
               the Salvation Army, United Way and the Catholic                        
               Church".                                                               
               * * * the foundation will limit its currect [sic] fund                 
               raising activities to raising funds directly from its                  
               officers, directors and their immediate familites                      
               [sic], friends and business associates.                                






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