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501(c)(3). An organization will not be so regarded if
more than an insubstantial part of its activities is
not in furtherance of an exempt purpose. [Sec.
1.501(c)(3)-1(c)(1), Income Tax Regs.]
As already noted, SNI desires recognition of exemption from
the date the Form 1023 was received by the IRS, and not
retroactively. As also indicated above, SNI responded to a
request for a detailed description of its contemplated future
activities by reiterating a description of the activities in
which Valfer was already engaged. In its brief SNI concedes that
“the Petitioner, SNI, and David A. Valfer are one and the same.”
However, SNI challenges respondent’s contention that
contributions to SNI inure to Valfer’s benefit, because “The
plain fact is that no contributions of either money or services
have been received by SNI from any source other than Mr. Valfer.”
Nevertheless, Valfer, responding on behalf of SNI to the July 19,
1999 IRS letter, stated that he would like to receive “a Tax
Exempt letter to apply for a grant to procure a computer,
printer, and related software.” Since the affairs of SNI and
Valfer are irretrievably intertwined, as Valfer/SNI readily
admits, the benefits Valfer plainly hopes to obtain via the “Tax
Exempt letter” would obviously inure to Valfer himself.
Similarly, SNI has not shown that compensation for Valfer’s
serving as a Shomer at a rate of $75 to $90 per 12-hour vigil
would not inure to a private individual. Petitioner SNI has not
shown that the recipients of Valfer’s services as a Shomer are
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Last modified: May 25, 2011