CRSO - Page 3

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               Petitioner characterizes its sole activity as receiving                
          rental income from commercial real estate that it owns and                  
          distributing the net proceeds to Chi Rho Corp. (Chi Rho), a                 
          publicly supported section 501(c)(3) organization.                          
          Articles of Incorporation                                                   
               Petitioner’s articles of incorporation state that it is                
          organized and shall be operated exclusively for charitable,                 
          educational, and scientific purposes within the meaning of                  
          section 501(c)(3), by making distributions to carry out the                 
          charitable, educational, and scientific purposes of Chi Rho.  The           
          articles of incorporation further state that petitioner “is                 
          organized to act as a supporting organization for Chi Rho                   
          pursuant to section 509(a)(3)”.                                             
          Board of Directors and Officers                                             
               Petitioner’s initial board of directors consisted of three             
          individuals:  Hudson R. Staffield, Cynthia T. Staffield                     
          (collectively, the Staffields), and Peter A. Witherspoon.  These            
          three individuals also served as petitioner’s president,                    
          secretary/treasurer, and vice president, respectively.  They each           
          devoted, on average, about 3 hours of service per week to these             
          Petitioner’s Real Estate Acquisitions                                       
               In 1997, the Staffields purchased two commercial retail                
          buildings (the real estate) that are part of a retail center in             

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Last modified: November 10, 2007