Peoples Prize - Page 5

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          qualified section 501(c)(3) organization exempt from Federal                
          income tax under section 501(a).                                            
                                     Discussion                                       
               A tax exemption is a matter of legislative grace, and an               
          organization seeking an exemption must prove that it “comes                 
          squarely within the terms of the law conferring the benefit                 
          sought”.  Nelson v. Commissioner, 30 T.C. 1151, 1154 (1958); see            
          also Fla. Hosp. Trust v. Commissioner, 103 T.C. 140, 153 (1994),            
          affd. 71 F.3d 808 (11th Cir. 1996).                                         
               An organization may seek tax-exempt status before it begins            
          operations, but the administrative record must set forth                    
          sufficient detail about its prospective operations to provide the           
          basis for the granting of the exemption.  Nationalist Movement v.           
          Commissioner, 102 T.C. 558, 572 (1994), affd. 37 F.3d 216 (5th              
          Cir. 1994); La Verdad v. Commissioner, 82 T.C. 215, 219 (1984);             
          World Family Corp. v. Commissioner, 81 T.C. 958 (1983); Church of           
          Boston v. Commissioner, 71 T.C. 102, 105 (1978); Hancock Acad. v.           
          Commissioner, 69 T.C. 488, 492 (1977).                                      
               Petitioner has, for the most part, provided only                       
          generalizations in response to repeated requests by respondent              
          for more detail on prospective activities.  As petitioner states            
          in its reply brief:                                                         
               once momentum for our first prize is substantial, we will              
               launch additional prizes to benefit of humankind.  The                 
               prizes will be chosen only after months and years of                   
               extended deliberation and collaboration.  We will                      





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