Wayne Baseball, Inc. - Page 3

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          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           
               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 on           

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Last modified: May 25, 2011