- 16 -
Conference of the Free Church of Am. v. Commissioner, 71 T.C.
920, 927 (1979); Levy Family Tribe Found., Inc. v. Commissioner,
69 T.C. 615, 619 (1978). Consequently, an examination of the
administrative record in the instant case for evidence that the
enumerated activities of the Articles will further an exempt
purpose is appropriate.
We understand petitioner’s contention to be that it is a
school organized to disseminate theory to the public at-large via
petitioner’s Web site and to engage in the practical application
of such theory through its five divisions. Petitioner includes
banking activities among such practical applications.
As noted above, the Articles expressly empower petitioner to
identify socioeconomic problems and provide economic solutions.
Article I of the Bylaws establishes United Bank as one of
petitioner’s five organizational divisions but does not further
describe the organization or operations of United Bank.
Petitioner’s Web site stated that United Bank of
Amend16robertwirengard would provide banking products and
services to individuals and businesses. According to the Web
site, such services include establishing IRAs, pooling funds,
electronic payroll deposits for small firms and possibly for
United Health Payers, accruals, disbursements, and providing
micro loans. In its letter of June 20, 2002, petitioner stated
that United Bank is primarily distinguished from commercial banks
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