Amend16RobertWirengard - Page 11

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               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.                                                    





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Last modified: May 25, 2011