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The amended Form 1023 did not list specifics as to petitioner's
operations, including the manner in which petitioner would effect
its amended primary purpose. The amended Form 1023 did not
address any safeguards against private inurement.
On April 9, 1996, the Commissioner mailed a letter to
Mr. Tully, in his capacity as petitioner's vice president,
explaining that petitioner had not yet described its operations
in sufficient detail. The letter set forth four items of
information that the Commissioner lacked as to petitioner
including a definition of the term "financially strap" as set
forth in the amended Form 1023.
By way of an undated letter, Mr. Tully responded to the
Commissioner's letter of April 9, 1996. The response was
generally vague as to the information sought. As to the
definition of the term "financially strap", the letter stated:
This organization defines the term "financially
strap" as a temporary condition wherein the person, or
family, under consideration is without "immediate funds
in sufficient amount to provide the very necessities of
life for the present day, or week, at most".
It is not to bail out any person or family from
their current financial psoition [sic]. Rather, it is
a temporary means of relief that is intended to assist
that person or family in their immediate need of foods
and or lodging for at least a day or two, perhaps a
week at the most until they can get on relief or find
other assistance, if that be the case.
It is to make sure that the person or persons in
question do not have to go hungry over night or not
have a safe place to stay.
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