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501(c)(3) charitable organization and, therefore, is not exempt
from Federal taxation under section 501(a). Pursuant to section
7428 and title XXI of the Tax Court Rules of Practice and
Procedure, SNI seeks a declaratory judgment that it is a
qualified organization under section 501(c)(3). The issue for
decision is whether SNI operates exclusively for charitable
purposes. Unless otherwise indicated, all section references are
to sections of 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.
SNI was incorporated on April 7, 1976, under the Nonprofit
Corporation Law of Pennsylvania. Its principal office is located
in Hartford, Connecticut. The founder, sole director, and
officer of SNI is David A. Valfer (Valfer).1
1 In response to a question posed by an IRS Exempt
Organization Specialist as to how the name “Salvation Navy”
relate(s) to the organization, SNI responded as follows:
On New Year’s Eve, 1975, at a police station in Boston,
MA, when told that David got kicked out of the
Salvation Army shelter, the policeman told him to go to
the Salvation Navy. He returned to Philadelphia, PA
Articles of Incorporation were drawn up, then on to the
(continued...)
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