At Cost Services, Inc. - Page 13




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               Besides petitioner’s uncorroborated and inflammatory                   
          accusations, the record is void of any suggestion that                      
          petitioner’s application for tax-exempt status was denied because           
          petitioner’s sole founder, director, and officer is a black male.           
          Instead, based on our above analysis, we hold that the                      
          Commissioner’s denial was correct and based on a determination              
          that petitioner is not operated exclusively for exempt purposes             
          under section 501(c)(3).                                                    
               For the reasons stated, we conclude that petitioner is not             
          operated as a section 501(c)(3) organization.  We have considered           
          the remaining arguments of petitioner, and they either are                  
          irrelevant or otherwise lack merit.                                         
                                                  Decision will be entered            
                                             upholding respondent’s                   
                                             determination.                           





















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