- 19 -
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
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: March 27, 2008