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