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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
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 on
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