Solutions Plus, Inc. - Page 19




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         train individuals to improve or develop their capabilities or                
         instruct the public on subjects useful to individuals and that               
         are beneficial to the community.  See Am. Campaign Acad. v.                  
         Commissioner, 92 T.C. 1053, 1064 (1989); sec. 1.501(c)(3)-                   
         1(d)(3)(i), Income Tax Regs.                                                 
              Petitioner stated that it was in the process of developing              
         free educational pamphlets for its DMP clients that would focus              
         on financial literacy and financial soundness.  However, other               
         than a one-page handout, petitioner did not provide respondent               
         with copies of the actual materials that it professed would be               
         provided to consumers, nor did petitioner describe in any detail             
         the content of any such materials.  Petitioner’s origination                 
         script does not mention, describe, or offer to send any                      
         educational materials to a caller.  The only information that                
         petitioner’s script discusses is the sending of literature about             
         petitioner’s DMP and associated programs, such as its credit                 
         report analysis service.  In short, the administrative record                
         does not contain copies of any meaningful educational program or             
         educational materials that petitioner might send to a caller.                
              Petitioner also stated that it plans to provide seminars and            
         workshops to high school and college students on developing and              
         maintaining sound financial management skills, and it provided               
         outlines of the planned curricula.  The invitations indicate that            
         the student audience needs education on financial management and             







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Last modified: March 27, 2008