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Petitioner, in a letter dated June 18, 2002, supplemented
its Form 1023 disclosure to conform to the information requests
contained in the April 19, 2002, letter. Petitioner, by that
same correspondence, notified respondent of its intention to
submit a Form 1024 for joint processing with petitioner’s Form
1023. Petitioner submitted the Form 1024 on July 8, 2002.
On September 27, 2002, respondent sent petitioner a letter
(the September 27, 2002, letter) containing 31 enumerated items
outlining various insufficiencies and disparities regarding
petitioner’s Form 1023 and Form 1024. The identified
inadequacies concerned, among other things, certain provisions in
petitioner’s articles of incorporation as well as representations
in the application concerning petitioner’s fundraising activities
and sources of financial support, the composition of its
membership and the nature of its operations. The September 27,
2002, letter also stated that, if respondent were to determine
that petitioner otherwise qualified as an organization described
in section 501(c)(3), the extensive organizational control
petitioner’s chairman apparently possessed would render it a
private foundation. The September 27, 2002, letter expressly
imposed a 30-day deadline for petitioner to respond.
On November 18, 2002, respondent sent a letter to petitioner
noting that the response deadline to the September 27, 2002,
letter had lapsed with no communication having been received, and
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