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sell and deliver within 365 days more than 100,000 cars
and/or light trucks with the proven ability to go ONE
MILLION KILOMETERS without replacement parts (excluding
tires, brake pads, and filters).” This prize will be
awarded to an automobile manufacturing company when it can
demonstrate to it’s [sic] competitors, to the media, and to
Peoples Prize that it has reached the goal. The economic
and other benefits to humanity will be enormous, but
proportionally, the most beneficial impact will be felt by
the working poor and low income persons in all lands by
increasing the supply of reliable used vehicles and reducing
the cost per year to purchase and maintain a motor vehicle.
The prizes will all be for long-term, bold, large objectives
that would seem to be impossible, such as a million-
kilometer car, a universal alphabet, etc. We will actively
solicit ideas for further prizes. They must be of direct
general benefit to the well being of humanity, particularly
to large numbers and future generations, and not to a
limited few (such as a cure for an extremely rare disease).
There will be no prizes for space exploration. We
anticipate maintaining only a small number of prizes at a
time.
On March 11, 2002, respondent issued a proposed adverse
ruling as to petitioner’s exempt status. Petitioner filed a
protest to the proposed adverse ruling on April 17, 2002. On
August 15, 2002, respondent issued a notice of determination
denying petitioner’s exempt status and stated as reasons for the
denial:
You have not established that you are operated exclusively
for exempt purposes within the meaning of section 501(c)(3)
of the Code. Your primary activity is the promotion of the
private interests of for-profit companies rather than the
promotion of a public charitable purpose. Furthermore, you
have failed to establish that your activities serve to
lessen the burdens of government within the meaning of
section 501(c)(3) of the Code.
On November 18, 2002, petitioner filed a timely petition for
declaratory judgment seeking a determination that it is a
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