CRSO - Page 5




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          Petitioner’s Application for Exemption                                      
               On October 15, 2001, petitioner submitted to respondent Form           
          1023, Application for Recognition of Exemption Under Section                
          501(c)(3) of the Internal Revenue Code.  Part II of Form 1023               
          requests a “detailed narrative description of all the activities            
          of the organization--past, present, and planned.”  In response to           
          this inquiry, petitioner’s application stated:                              
               CRSO owns real estate in Wenatchee, Washington, which                  
               is used as a shopping center.  Its revenue is derived                  
               from triple net leases on that property to unrelated                   
               third parties.  CRSO is a “supporting organization” for                
               Chi Rho Corporation, a California corporation holding a                
               Section 501(c)(3) exemption.                                           
          Petitioner’s Income Tax Returns                                             
               For taxable years 2001, 2002, 2003, and 2004, petitioner               
          reported the following figures on its Forms 990-T, Exempt                   
          Organization Business Income Tax Return:                                    
                          Gross                                                      
                           unrelated              Unrelated Unrelated                 
                           debt-      Average    business        business             
               Gross    financed        acquisition   taxable    income               
          Year     rents   income       debt ratio    income       tax                
          2001   $275,570  $144,233     52.34%    $37,684        $5,653               
          2002    280,577   147,107     52.43     50,234         7,559                
          2003    254,317   130,643     51.37     30,064         4,510                
          2004    228,116   113,168     49.6      16,655         2,498                

          Denial of Petitioner’s Application for Exemption                            
               By letter dated November 8, 2002, respondent’s Exempt                  
          Organizations Division proposed to deny petitioner’s request for            








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