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requirements. See sec. 7428(b)(3); Rule 210(c). The case was
submitted for decision under Rule 122 upon the stipulated
administrative record. For purposes of this proceeding, the
facts and representations contained in the administrative record
are accepted as true, see Rule 217(b), and are incorporated
herein by this reference. The issue for decision is whether
petitioner is operated exclusively for charitable purposes within
the meaning of section 501(c)(3).
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner, a nonprofit corporation, with its principal
place of business at Warren, Michigan, was incorporated under the
laws of Michigan on February 1, 2000, with its purpose being “To
create and administer prizes for humanitarian goals. The prizes
will be broad based, consisting of donations of no more and no
less than $1.00 (one dollar US currency) per person.”
Petitioner’s Form 1023, Application for Recognition of
Exemption Under Section 501(c)(3) of the Internal Revenue Code,
was filed on May 14, 2001. Petitioner supplemented the
information contained in Form 1023 through correspondence with
respondent during the remainder of 2001 and into early 2002.
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Last modified: May 25, 2011