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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 its
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