- 11 - considered to be a welfare arrangement for employees and their family, our community; United Affiliations, is the legal channel that will allow our actual “reach- out” to involve all community members - from both private and government sectors, as well as all ranges of persons or associations within each - and for us to work together as individuals or groups for common goals, for example, or for affordable healthcare (a learning and application process, to the benefit of everyone); and Circle of Life Ministry, about getting food, shelter and healthcare for each other (again to the community’s welfare, and while dealing with the common notions of conscience or faith based charity). The letter distinguished petitioner from founder and board member Robert Wirengard, who “petitioned and lobbied” Federal and State Government officials and, in December of 2000, presented a healthcare model to the Health Care Advisory Board of Hillsborough County.4 In a letter dated October 20, 2003, respondent issued a final adverse ruling with respect to petitioner’s claim for exemption. Respondent based the ruling on his determination that petitioner failed to establish that: (1) Petitioner was organized exclusively for exempt purposes; (2) petitioner was operated exclusively for exempt purposes; (3) petitioner’s net earnings will not inure to the benefit of private individuals or serve private interests; and (4) petitioner was not an “action” organization within the meaning of section 1.501(c)(3)-1(c)(3), Income Tax Regs. 4Robert Wirengard proposed that government pay the costs of healthcare services for individuals to the extent of the average costs for such services.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011