- 3 - 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007