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On or about September 1, 1999, petitioner filed a
Form 1023, Application for Recognition of Exemption Under
Section 501(c)(3) of the Internal Revenue Code, with the
Internal Revenue Service at Baltimore, Maryland. In its
Form 1023, petitioner asked that it be recognized as a
section 509(a)(3) supporting organization. It listed
Keswick, Parklane, and Bedford as the supported
organizations. The Form 1023 states that Keswick receives
80 percent of petitioner's income, or approximately $26,000
per year, and that Parklane and Bedford each receive 10
percent of petitioner's income, or approximately $3,300 per
year.
Along with its Form 1023, petitioner submitted a
letter from Keswick's chief financial officer which
describes petitioner's participation in Keswick's
activities for 1996. According to the letter, there were
"149 participants served in the Adult Day Services Center
in 1996", of whom "29 were recipients of Cuddeback funds."
The letter states that "Keswick offers grants to needing
[sic] participants" in Keswick's "Adult Day Services
Center" that defray 40 or 50 percent of the full charge of
the program for the participant. The letter further
explains that the first 25 percent of the "grant" is
covered by Keswick and the remaining 15 to 25 percent comes
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Last modified: May 25, 2011