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section 501(c)(3). The issue for decision is whether petitioner
operates exclusively for charitable purposes. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect at the time the petition was filed, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
The administrative record, which includes all of the facts
upon which the Commissioner made the final adverse determination,
was submitted to the Court under Rule 217(b)(1) and is
incorporated herein by this reference.
Petitioner is a nonprofit Delaware corporation with its
principal office located in New York, New York. The sole
founder, director, and officer of petitioner is Matthew Marion
Fondel (Fondel), who has a bachelor’s degree in electrical
engineering from Northwestern University. Before founding
petitioner, Fondel worked temporary service jobs for 4 years
through a number of temporary service agencies.
On Form 1023, Application for Recognition of Exemption Under
Section 501(c)(3) of the Internal Revenue Code, petitioner stated
that its principal purposes are to:
(a) eliminate poverty for inner city minorities
associated with long-term unemployment and under-
employment and combat the racial prejudice these
individuals face in the conventional work place;
(b) promote social welfare by providing a means of
obtaining a lawful income to inner city minorities
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Last modified: May 25, 2011