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in that United Bank is neither incorporated nor a member of the
FDIC. Rather, Robert Wirengard assumes all liability related to
United Bank. Petitioner stated that loans were to be “of micro-
level (small) nature to help <small’ people economically to get
on their feet”. Petitioner provided respondent with a sample
microloan note, which imposed a 6-percent interest charge.
According to petitioner, as of June 20, 2002, United Bank had
made a single loan, which resulted in default.
Respondent contends that United Bank does not further any
exempt purpose. Petitioner contends that United Bank would help
the poor by extending microloans and contends generally that
petitioner lacks a profit motive.
Based upon our review of the record, we conclude that,
through United Bank of Amend16robertwirengard, petitioner is
empowered to engage in activities not in furtherance of an exempt
purpose. The record reveals that United Bank would carry on the
activities of a commercial bank, such as extending personal and
commercial loans for a stated interest. Petitioner’s stated
purpose of extending loans to low-income individuals and small
businesses, petitioner’s lack of profit-motive, and United Bank’s
lack of FDIC insurance do not establish that the commercial
banking activities of United Bank would further an exempt
purpose. The activities of United Bank would constitute a
substantial part of the activities of Amend16robertwirengard.
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