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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.
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