National Paralegal Inst. Coalition - Page 4

               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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Last modified: May 25, 2011