Salvation Navy, Inc. - Page 2

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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.                                      
               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                

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