- 3 - later 20's. In addition to being players, these older team members serve as mentors who instruct and assist in the development of their younger teammates. Two of the veteran players also serve on petitioner's board of directors. Of the 25 team members, 3 have experience playing in the professional minor leagues. The team does not have a formal instructional program. To improve player performance, the team relies instead on informal interaction between the players in giving each other advice and on self-taught, hands-on training that occurs in game situations. On their own time and initiative, two players have assisted local high school athletes in the game of baseball, but this extracurricular coaching is not sponsored by petitioner. Petitioner sponsors the team by supplying uniforms, equipment, umpire fees, insurance, league fees, and miscellaneous expenses. The expenses of the team run typically between $5,000 and $9,000 per year. A substantial amount of petitioner's proceeds come from contributions made by Charles T. Freeman (Freeman). Freeman is president of petitioner, a director on petitioner's board, and also volunteers as the general manager of the team. On December 6, 1995, petitioner submitted a Form 1023, Application for Recognition of Exemption, under section 501(c)(3). Respondent issued an initial adverse determination onPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011