- 2 - 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 minoritiesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011