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members of a charitable class, or that the fees SNI proposes to
charge serve any purpose other than to provide a source of income
for Valfer. Cf. Rev. Rul. 76-244, 1976-1 C.B. 155 (granting
exempt status to an organization providing home delivery of meals
at cost or less to financially distressed elderly and handicapped
persons).
Section 501(c)(3) provides for tax-exempt status for
corporations, and any community chest, fund, or foundation,
organized and operated exclusively for, among other things,
charitable purposes. It does not provide exemption for an
individual engaged in various activities, charitable or
otherwise. Insofar as can be ascertained from the administrative
record, Valfer engaged in various commendable activities--perhaps
sometimes in the name of SNI--but the activities were those of
Valfer, not SNI.
We accordingly conclude that SNI is not operated as a
section 501(c)(3) organization.
Decision will be entered
for respondent.
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Last modified: May 25, 2011