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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
positions.
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