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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.
Valfer.
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
1(...continued)
Department of State in Harrisburg, paid 75 dollars and
was incorporated on April 7, 1976.
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Last modified: May 25, 2011