Salvation Navy, Inc. - Page 3

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               On May 2, 1999, SNI filed a Form 1023, Application for                 
          Recognition of Exemption Under Section 501(c)(3) of the Internal            
          Revenue Code, with the IRS, seeking recognition of exemption                
          under section 501(c)(3) of the Internal Revenue Code.  In its               
          Articles of Incorporation, SNI stated that one of its purposes is           
          to “find out where one goes when he or she leaves”, and that SNI            
          “does not contemplate pecuniary gain or profit, incidental or               
          otherwise.”  On the Form 1023, SNI recited that its activities              
          include charitable work performed on a volunteer basis by                   
          petitioner’s founder and Chief Executive Officer (CEO), David A.            
               SNI further indicated on Form 1023 that its sources of                 
          financial support came solely from Valfer’s Supplemental Social             
          Security income, aid to the disabled income, medicaid payments,             
          and food stamps.  SNI also indicated that it had no fund-raising            
          program in place and had no revenue or expenses during the                  
          taxable years 1995 through 1998.  The administrative record does            
          not reveal that SNI kept any financial books and records.                   
               Attached to the Form 1023 were several documents containing            
          citations and statements of recognition commemorating Valfer’s 20           
          years of community service to the City of Hartford, Connecticut,            
          which included his volunteer activities at a Hartford weekend               

               Department of State in Harrisburg, paid 75 dollars and                 
               was incorporated on April 7, 1976.                                     

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