- 11 - presentation entitled “On the Right Track”, which includes material on understanding credit reports and credit scores, establishing credit, and borrowing techniques. Petitioner received two invitations in 2006 to make presentations on financial management to students. 3. Petitioner’s Protest After considering Mr. Dennis’s response, respondent advised petitioner that it had been identified as an organization engaging in at least one of the following activities: Credit counseling, credit repair, debt consolidation, financial education, money management, budgeting, or a related financial activity. Respondent provided petitioner with a copy of a comprehensive analysis as to whether entities engaged in these activities can qualify as organizations described in section 501(c)(3). Respondent also provided petitioner with a detailed statement of facts and law as to why it appeared that petitioner did not qualify for tax-exempt status under section 501(c)(3) and gave petitioner 30 days to file a protest. Petitioner then submitted to respondent a protest stating that its activities would mirror those in Consumer Credit Counseling Serv. of Ala., Inc. v. United States, 44 AFTR 2d 79-5122, 78-2 USTC par. 9660 (D.D.C. 1978), because petitioner’s activities contemplated education of the public and its DMP activity was merely incidental. Petitioner attached to itsPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: March 27, 2008