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The balance sheet submitted as part of petitioner's Form
1023 is set out below:
Balance sheet 7/31/99
Assets
Cash $197,289
Bonds and notes receivable 100,500
Corporate stocks 611,770
Other investments 17,033
Total assets 926,592
Liabilities
Total liabilities -0-
Fund balances or net assets
Total fund balances or net assets (926,592) (sic)
Total liabilities and fund balances or net assets 926,592
By letter dated November 16, 1999, respondent
recognized petitioner as an organization described in
section 501(c)(3) but issued a proposed adverse ruling as
to petitioner's private foundation classification. In
pertinent part, the adverse ruling states as follows:
Information submitted states the support provided
by the organization revealed that in 1999 the
organization distributed 8% percent [sic] of it's
[sic] income to Kerswick [sic] and 1% percent
[sic] each to Bedford Park Presbyterian Church
and Parklane Baptist Church.
You submitted a letter dated March 17, 1997 from
Keswick in which it states that the grant is of
a significant benefit to its budget. However,
the amount of the grant in comparison to the
overall annual income of each recipient
organization far exceeds the gross income and
net investment income of the trust. Thus, we
find that the support provided by the trust is
not sufficient to ensure the attentiveness of
the charities to the operations of the organi-
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