- 13 - the information provided by petitioner shows that it expected revenue from payments by creditors and from customers who would be attracted to petitioner by traditional advertisements through networks of organizations having members with credit issues. In addition, respondent stated that petitioner had researched companies that would purchase credit counseling leads supplied by petitioner. F. Proceedings in the Tax Court Petitioner timely filed the petition seeking a declaratory judgment under section 7428 with respect to its initial qualification for exemption as an organization described under section 501(c)(3). In the petition, petitioner states: Solution Plus Inc. is requesting tax exemption status under 501(c)(3) of the Internal Revenue Code. Solution Plus filed form 1023 on February 25, 2005 and did not receive a response until November 11, 2005. In the IRS letter dated November 11, 2005 there was a request for additional information inwhich detailed questions were raised and answered in reference to Solution Plus operations. Solution Plus primary goal is to educate individuals about the pit-falls of improper debt management. Solution Plus was formed to give the general public a fair opportunity to educated [sic] and counsel individuals who are going through hard financial distress. On September 19, 2006, the IRS sent Solution Plus a final denial of tax-exempt status without providing adequate reasons for their denial. Its appears that the IRS is focusing on our use of Debt Management Plans, but the DMP is only a minimal part of Solution Plus revenue. [Reproduced literally.] As stated above, the petition and designation of place of submission were the last documents that petitioner submitted to the Court in the instant proceeding.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: March 27, 2008