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IRS Questions
Up EFEF BYLAWS Tax-Exempt Application IRS Questions REV-RUL 63-252 Response to Questions Tax-Exempt Approval

Internal Revenue Service
Director, Exempt Organizations
Rulings and Agreements

Date: September 16, 2002

Ehume Foundation Education Funds
P.  O. Box 13853
Greensboro,  NC 27415

Department of the Treasury
P.O. Box 2508  -  Room 4-522
Cincinnati, Ohio 45201

Employer Identification Number:
     
56-2258937
Person to Contact  -  ID#:
     
Michael Hanson -#31-07856
Contact Telephone Numbers
:
     513-263-4460      Phone
     513-263-4488      FAX
Response Due Date:
    
10/7/2002

Dear Sir or Madam:

Before we can determine whether your organization is exempt from Federal income tax, we must have enough information to show that you have met all legal requirements. You did not include the information needed to make that determination on your Form 1023, Application for Recognition of Exemption Under Section 501(c) (3) of the Internal Revenue Code.

To help us determine whether your organization is exempt from Federal income tax, please send us the requested information by the above date. We can then complete our review of your application.

If we do not hear from you within that time, we will assume you do not want us to consider the matter further and will close your case. In that event, as required by Code section 6104{c) , we will notify the appropriate state officials that, based on the information we have, we cannot recognize you as an organization of the kind described in Code section 501{c) {3) .As a result, the Internal Revenue Service will treat your organization as a taxable entity. If we receive the information after the response due date, we may ask you to send us a new Form 1023.

In addition, if you do not provide the requested information in a timely manner, we will consider that you have not taken all reasonable steps to secure the determination you requested. Under Code section 7428(b) (2), your not taking all reasonable steps in a timely manner to secure the determination may be considered as failure to exhaust administrative remedies available to you within the Service. Therefore, you may lose your rights to a declaratory judgment under Code section 7428.

If you have any questions, please contact the person whose name and telephone number are shown in the heading of this letter.

 

Enclosure 

Sincerely yours,

  (original signed by Michael J. Hanson)

 Michael Hanson  
 
Exempt Organizations Specialist

                                                                             Letter 1312 (DO)

               

Page 2

Ehume Foundation Education Funds
56-2258937

Note: Your response to this letter must be submitted over the signature of an authorized person or of an officer whose name is listed on page 3 of the application. If we do not receive your complete response by the due date, we will close your case temporarily. If you submit your response within 90 days after your case has been closed, we will re-open it for processing and you will neither have to file a new application nor lose your user fee.

PLEASE ATTACH A COPY OF THIS LETTER TO ALL CORRESPONDENCE

Additional Information Requested:

1. Please review Revenue Ruling 63-252. It states that contributions to certain domestic charitable organizations are deductible if it can be shown that the gift is, in fact, to or for the use of the domestic organization, and that the domestic organization is not serving as an agent for, or channel for, a foreign charitable organization. In reaching this conclusion, the revenue ruling states that it seems clear that the requirements of section 170(c) (2) (A) of the Code would be nullified if contributions inevitably committed to go to a foreign organization were held to be deductible solely because, in the course of transmittal to the foreign organization, they came to rest momentarily in a qualifying domestic organization. In such cases, the domestic organization is only nominally the donee; the real donee is the ultimate foreign recipient.

  1. How is your organization different or similar to the organizations described in Rev. Rul. 63-252?
  2. Does your organization maintain control and responsibility over the use of any funds granted to foreign organizations? If yes, explain in detail how you exercise such control?
  3. Will anyone from your organization make any field investigations to ensure your funds are being used properly? If yes, how often?
  4. Does your organization have full control and discretion over funds donated to you or does the foreign organization control the funds?
  5. How does your organization ensure that the funds you donate to Ehume Community School are used for the purposes that they were intended? Please explain.

Page 3

Ehume Foundation Education Funds
56-2258937

PLEASE DIRECT ALL CORRESPONDENCE REGARDING YOUR CASE TO:

US Mail:

Internal Revenue Service
Exempt Organizations
P. 0. Box 2508
Cincinnati, OH 4520l
ATT: Michael Hanson
          Room 4-522

Street Address:

Internal Revenue Service
Exempt Organizations
550 Main St, Federal Bldg
Cincinnati, OH 45202
ATT: Michael Hanson
          Room 4-522

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