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TAM 202302013

Religious, Charitable, etc., Institutions and Community Chest

Official textIRS Written Determinations (PLR · TAM · CCA)irs.gov
Summarize

# Issues

(1) Should tax exemption under section S0l(c) (3) of the Internal Revenue Code be revoked because (1) its income inured to the benefit of its principal officers and and (2) the organization has not engaged in any exempt activity during its entire existence?

(2) Is liable for the penalty
Is
Facts: prescribed under IRC Section 6652 {c) (1) (A) (ii)? an organization exempt from of the Internal Revenue Code for failing to file returns for the years ending Background tax under section S0l(c) (3) complete and accurate Form , and ?
The , hereinafter " was incorporated on in the State of by received its exemption from federal income tax under Section S0l{a) on as an organization described under S0l(c) (3; and further classified as a publicly supported organization under section 170(b) (1) (A) (vi). is required to file Form The organization's Articles of Incorporation state: the organization is organized exclusively for charitable, religious, educational, and scientific purposes, including, for such purposes, the making of distributions to organizations that qualify as exempt organizations under sect ion 501 ( c) ( 3) of the Internal Revenue Code, or corresponding section of any future federal tax code The organization's bylaws state in Article VII, Section 7.01:
PROHIBITION AGAINST SHARING IN CORPORATE EARNINGS No director, trustee, officers or employee of or member of a committee of or person connected with the Corporation shall receive at any time any of the net earnings or pecuniary profit from the operations of the Corporation, and no such person or persons shall be entitled to share in the distribution of any of the corporate assets upon the dissolution of the Corporation.
1
Fonn886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number The organization's bylaws state in Article VII, Section 7.03:
DISSOLUTION OF THE ORGANIZATION Upon dissolution of this organization the remaining assets after all the debtors had been paid must be distributed to all exempt organizations within IRS 501 c3. None of the exempt recipients must be affiliated with the officers, directors, board members or any of the organization employees.
The organization's Form state:
Form
1 , Part IV, Narrative Description of Your Activities Said Corporation is organized exclusively for charitable. To provide crucial resources to the elderly, disable and displaced persons in our local community and in . Such crucial resources are foods, clothing, and transportation assistance to doctors' visits, including for such purposes, the making of distributions to organizations that qualify as exempt organizations within the Section 501 (c) (3) of the Internal Revenue Code of 1986 (or the corresponding provisions of any future United States Internal Revenue Law), as well as any lawful purpose, as authorized by law.
Form , Part V, Compensation and Other Arrangements with Your Officers, Directors, Trustees, etc., Line la, reports the organization's officers:
Name title Com:eensation Amount President None Secretary I Treasurer None Director None Director None Director None checked negatively "No" to line 2a, which asked are any of your officers, directors, or trustees related to each other through family or business relationships? If "Yes," identify the individuals and explain the relationship. also provided an attached statement, "#2a & 2c: At this time none of the officers are related but the organization has adopted conflict of interest policy." and Per IDR 2 & 3 response, mother.
2 are cohabitants based on public record research. is mother, is and are cohabitants.
1 The organization's bylaws include this stated purpose in Article II Purpose, Section 2.01 2 This report asserts in the government's position that organization was controlled by and with no board oversight.
2
Form 886-A
1994)
Name of taxpayer
EXPLANATIONS OF ITEMS
Tax Identification Number positively checked "Yes" to Line Sa which asked Do you or will you have any leases, contracts, loans, or other agreements with your officers, directors, trustees, highest compensated employees, or highest compensated independent contractors listed in lines la, lb, or le? If "Yes," provide the information requested in lines Sb through Bf. b Describe any written or oral arrangements that you made or intend to make. c Identify with whom you have or will have such arrangements. d Explain how the terms are or will be negotiated at arm's length. e Explain how you determine you pay no more than fair market value or you are paid at least fair market value. f Attach copies of any signed leases, contracts, loans, or other agreements relating to such arrangements. attached a narrative to question 8, stating" is exclusively for charitable service to the public. In purchasing or leasing we do not discriminate.
Our objective is to shop for the best goods, service and lease for the lowest price irrespective of the providers or sellers as long such businesses we are dealing with were not in violation of law". did not report it would incur rental expense on Part IX, Financial Data, Line 20, Occupancy (rent, utilities, etc.) during the , and years. also did not report occupancy expenses on its attached narrative of Part IX for through Form Part VIII, Line 4a, indicated that it would engage in mail, email, personal, phone, government grant & foundation solicitations; accept donations from website; etc. and checked that it would operate as a 509(a) (1) & 170(b) (1) (a) (vi) - an organization that receives a substantial part of its financial support in the form of contributions from publicly supported organizations, from a governmental unite or from the general public. checked negatively "No" when asked if the corporation intends to solicit charitable/ tax deductible contributions on its NONPROFIT INITIAL AUANNUAL LIST OF OFFICERS AND DIRECTORS form that it filed with the State of on Form reported its financial information on , &
Forms
Form , as follows:
Part I, Revenue, Expenses and Change in Net Assets of Fund Balances Contributions, Gifts & grants $ $ $ $ 3 Total Revenue $ $ $ $ and Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Exclusively all contributions were received from flow through corporations owned by Professional Fees $ $ Salaries, other comp $
Part II, Balance Sheets
Other Expenses
$
$
$
$
Total Expenses
$
$
$
$ and for-profit
Excess or Deficit
$
$
-$
-$
Cash BOY EOY Other Assets EOY Net Assets or Fund Balance $ $ $ $ $ $ $ $ $ $ $ Accounts receivable $ $ $ $ $ Part III, Statement of Program Service Accomplishments reported its primary exempt purpose was to "provide crucial resources to the elderly, disable and displaced persons in our local community and in Such crucial resources are foods [sic], clothing, and transportation assistance to doctor's visits reported on Line 28 that it provided food and clothing to over both and in - $ , $ , & $ in respectively. It also included$ on line 4 of Form for people in , and Line 29 reported that provided transportation assistance for doctor's visits - blank, $ & $ in and , respectively. Assistance for doctor's visits was included in the amount on Line 4 of Form for Line 30 reported that provided medical equipment to the sicks [sic] - and did not quantify the amounts. attached Schedule 0, Supplemental information, to its , and Form and Form , which listed the following "other" expenditure explanations and its "other asset":
4
Form886-A
Name of taxpayer
& Form
Forms
Schedule O Information
Transportation
Bank Fee
Feeding & Clothing in and
Liabbility Insurance
Promotion
Utilities
Receivable Loan
Amended
Accounting Fees
Auto Expenses
Benevolence
Transportation Assistance
Bank Charges
Feeding & Clothing
Insurance
License and Permits
Volunteers Meals and Snacks
Maintenance and Repair
Office Supplies
Postage and Shipping
Rent
Supplies
Telephone Exp
Travel
Utilities
Receivable Loan
EXPLANATIONS OF ITEMS
Tax Identification Number
Accounting Fees
Auto Expenses
Benevolence
Bank Charges
Feeding & Clothing
Insurance
Maintenance and Repair
Office Supplies
Postage and Shipping
Rent
Supplies
Travel
Transportation Assistance
License and Permits
Receivable Loan
Foreign Mission Exp
Insurance Expense
Postage & Shipping
Profession! & Legal Services
Sipplies Expense
Other Expenses & Fees & Pern
Telephone expense
Utilities s
Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Part IV, Officers Directors, Trustees, Key Employees reported the governing body as follows:
Name Average hrs per wk Compensation Treasurer , President , Secretary I , Director , Director , Director Part VI, Other Information checked negatively "No" to the following questions:
$
$
$
$
$
Line 33, "did the organization engage in any significant activity not previously reported to the IRS? If Yes, provide a detailed description of each activity in Schedule 0."
Line 38 (a) did the organization borrow from, or make any loans to, any officer director, trusted, or key employed or were any such loans made in a prior year and still outstanding at the end of the tax year covered by this return? (b) if yes, complete Schedule L, Part II and enter the total amount involved." Schedule L was not attached to the Forms Line 40 (b) "Did the organization engage in any section 4958 excess benefit transaction during the year, or did it engage in an excess benefit transaction in a prior year that has not been reported on any of its prior Forms or ? If yes, complete Schedule L, Part I." Schedule L was not attached to the
Forms
Information Document Requests
Form 4564, Information Document Request 1 (IDR 1) and initial exam letter was mailed to on to the organization's address , which is reported as the organization's mailing address on Form and Form Part I, Identification of the Applicant. is the reported address on the organization's Forms mailing address; on its bank statement mailing address; is also and personal residence; and is owned by Because correspondence mailed to the was 'returned to sender' / "vacant" subsequent mail certified & uncertified mail (such as Forms , Summons Noticee Copies) were mailed to The certified mailed items were 'returned to sender' as unclaimed.
6
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number A subsequent exam letter and IDR 1 was mailed4 on to The letter was returned to sender which labeled the address as "vacant". described its activity in IDR 1 response stating:
Since its establishment in , the have [sic) partnered with many hospital discharge planners and owners of independent living houses especially in & These Independent living houses independently may house to individuals and or families for a short time following hospital discharge, preventing them from being discharged to a shelter. There are at least independent living houses operating in and they have sheltered over people since While shelter is provided these house owners are not always able to meet the needs of these individuals and requires assistance from organizations such as the to provide meals and assistance to individuals until they are able to secure their own housing, transportation, and financing.
Here are a few addresses that have been supported by our organization since See Exhibit A for the listing.
The Board members of have a relationship with the community house owners and managers who identify independent living homes in the community. Known to our organization, independent living homes houses [sic) people of low income as well as no income. Due to this income deficiency, multiple adults share a living space so they can share the expenses and this leaves them little of nothing to survive on. The will provide these individuals food, transportation and sometimes pay a small fee for individuals to allow them to reside in certain homes for a short period of time until their financial restrictions are lifted. Before individuals are accepted into independent living houses, their incomes [sic) are verified by hospital case managers as well as house owners and managers. Keep in mind that the average monthly payment by the state of for persons are$ / month which they are expected to pay for housing food and maintenance.
The organization's response to IDR 1 omitted the names and contact information of the property owners and/or purported program coordinators of the temporary housing shelters. The examining agent contacted property owners from the addresses provided by to query their involvement in the organization's mission (providing temporary assistance to individuals, financial, and non-cash assistance) . ) responses were received, ( ) in writing and phone conversations were held. () individuals stated they had no affiliation with the organization, or that their property was not used to temporarily house 4 Second issuance of IDR 1 was mailed standard, i.e. uncertified 7 Schedule nurnbef or exhibit Foon 886-A EXPLANATIONS OF ITEMS Name of taxpayer Tax Identification Number individuals. No property owner reported they receive any form of assistance or aid from Notably, of the negative responses were from charities that operate homeless programs in , in which one stated it did not recognize ( ) as a collaborative partner and has no indication or evidence that it received support of any kind from private property owner stated they nnever heard of them" referring to the IDR 1 response did not provide contemporaneous receipts, invoices, credible explanations, or other satisfying documents to substantiate its exempt activity. Rather, substantiation consisted of hand-written notes prepared by The notes explained numerous cash withdrawals (discussed below} as» " Fast-food expenditures were described as" n, and lavish meals were described as" • Below is a sample of the handwritten explanations provided in IDR 1. The full expenditure listing consisted of pages:
• 11
8
Schedule numl>ef or exhibit
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax ldernlticalioo Number E ~
- tt
…
§
'$
1
"
1\
~
~
~ ..
… t
… was asked numerous times to substantiate its expenditures and activities in IDRs l, 2, 3, 4, & S, however, did not substantiate these expenditures to be charitable.
For instance, IDR 3, pertaining to years endins and asked, (6} provide any other substantiation for the organization's expenditures such as invoices, receipts and similar contemporaneous substantiation. responded "Question 6 Response: All receipts and invoices for substantiation has been submitted to your office already. If there are any specifics that you need clarification on, I will be happy to provide it." provided a loan agreement in response to IDR l dated agreement was post-dated, and covered funds previously borrowed by during and The agreement was signed by and and stated that loaned a total of$ {in } and re-payed$ (in The document further stated:
The
"The Remainder of the loan, $ of$ over a course of and end in will be repaid with no interest at a rate months. Repayment of the loan will commence on ,, As of , the outstanding loan balance of$ not been repaid by ( year and date in the loan agreement) 5 • appears to have months past the repayment 5 The exam of was expanded to year ending limited to addressing the cancellation of debt for the outstanding loan balance$ 9 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number provided a the lease were purportedly for lease agreement in its IDR 1 response. The parties of (landlord) and (tenant) and was executed use of personal residence ( ) . The term of the lease was years ( ) at a rental amount of dollars ($). The lease further stated that the agreement cannot be changed orally. The lease was signed by as Landlord and as tenant and representative of the stated in response to IDR 1 that organizational debit cards with individual(s) that possess debit card(s) ending that possessed both debit cards and IDR 3 asked and , and and ) . hold to identify the replied However, information reported that the debit card ending in was under name and debit card ending in was under name.
IDR 5 asked (question 4) to Identify all participating hospitals by name, address and the representative/ contact person's whom coordinated with as well as to provide the contact's name & telephone number to verify exempt activity. responded: "All major medical and mental health hospitals in has benefitted from our services including and many more. Discharge planners are individuals assigned to facilitate discharge and changes from time to time."
IDR 5 (question 5) asked: to provide the contract or agreement between your organization and each participating hospital identifying the description of services rendered by and remuneration received. responded: "There are no contract or agreement [sic] between hospitals and my organization as our organization was not pressured to do it but these individuals especially mental health patients need the services and we provided it [sic]."
IDR 5 (question 6) asked: Provide all Hospital discharging documents, power of attorney forms, or any other required documentation; for all patients, authorizing you and your organization to take care or custody of each outgoing patient. responded: "Absolutely not. All hospital discharge paperwork are covered under HIPAA. Your word custody tells me you have no clue about the voluntary nature of our organization. The organization will not be fighting for custody for some individuals it needs to help." has not provided substantiation that it's a HIPAA6 covered entity. did not provided evidence that it furnishes, bills, or receives payment for healthcare 6A HIPAA transaction is an exchange of electronic information between two Covered Entities to carry out financial or administrative activities related to healthcare. An example would be when a healthcare provider sends a claim to a health plan to request payment for services.
10
Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number services, nor did it provide evidence that it engages, transmits or sends any covered transaction(s) electronically in the normal course of business.
IDR 5 (question 7) asked to provide for each patient assisted: a) full name b) ssn c) phone number d) discharging hospital and address e) discharging date f) location of temporary housing including name, address and phone number of each individual housing provider g) dates patient stayed in the temporary location h) agreement contract between the organization and each temporary housing provider i) records detailing and explaining the exact type of assistance provided for ii) each individual named patient j) records identifying the amount, or each fund expended for on behalf of each individual named patient k) all documents reviewed and used to approve and verify each discharge patient qualifies as low-income.
1) Provide reports provided by to each discharging hospital by your organization responded: Absolutely not.
IDR 5 (question 8) asked to "Explain your role in the final care and disposition of each patient once the temporary housing has expired." responded: "Our organization's role is to provide safe housing, food, transportation, assist with med co-pays until the individual is situated in the community this may include making use of shelters".
IDR 5 (question 9) asked Explain what type of follow up visit is conducted by either your organization or the discharging hospital, provide supporting documentation responded: Again, this is something done voluntarily to ease the burden on hospitals and the city/state. There are no contracts or timetable or babysitting by the discharge hospital. All the hospitals care about is that the patients have left their doors that is why there are so many persons and a broken state program with no assistance of these individuals. and signature authority over the and Treasurer, respectively.
Disqualified Persons are organizational managers and possess organization's account are the organization's President and Secretary/ signed all Forms 11 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer
The organization's transactions during Expenditures conducted by include:
Tax Identification Number account , & Bank Accounts revealed the following (debit card ending ) worth noting ATM cash withdrawals conducted at various totaling $ classified as "feeding and clothing the underprivileged" on general ledger (G/L). explained these withdrawals in response to IDR 1 as" " (listed for each withdrawal) Daily & reoccurring fast-food purchases, & purchases totaling$ were classified on 's G/L as feeding and clothing the underprivileged. totaling$ and Lavish meal at Buffet totaling$ the underprivileged. as a" was classified on G/L as feeding and clothing purchase of$ clothing the underprivileged. expense as" explained this expenditure in response to IDR 1 classified on G/L as feeding and response to IDR 1 explained this Expenditure totaling$ for classified as an auto expense. The organization's response to IDR 1 explained this expense as Note that in in is an online ticketing company; the is an The expenditure is payment for an entertainment event Expenditure totaling$ classified as a supplies expense. The organization's response to IDR 1 explained this expense as "entertainment"
Summary of debits from card ending ATM W/D $ Daily meals $ &Buffets $ Other entertainment $ Purchased items/Other $ , Groceries etc.
~
Total $
12
Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number did not provide contemporaneous substantiation to support these expenditures served an exempt purpose.
Expenditures conducted by include:
(debit card ending ) worth noting Date Amt $ $ $ Location IDR Substantiation: classification Sponsored for Couple reported as "Family Entertainment" reported as "Family Entertainment"
The above expenditures were reported on [SIC} G/L as "Feed, Cloth, Underpriv"
Daily & reoccurring fast-food purchases, & purchases totaled$ and were classified on G/L as "feeding and clothing the Airfare "travel" totaling$ contemporaneous substantiation. provided no further explanation or A$ teller cash withdrawal conducted on G/L as feeding and clothing the underprivileged. further explanation or contemporaneous substantiation. classified on provided no ~ check numbers , and for property maintenance, repairs and cleaning totaling$ Check numbers totaling$ for bookkeeping/ return preparation; miscellaneous unexplained checks totaling$ provided no contemporaneous substantiation to prove these expenditures served an exempt purpose.
ATM W/D
Daily meals
Summary of
Lavish Meals & Buffets
Travel debits from card ending $ $ $ $ 13 & other debits:
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Purchased items/Other $ ' Groceries etc.
Total debit card $
Total teller w/d & checks
_§i
Total $ did not provide contemporaneous substantiation these expenditures served any exempt purpose. also provided interest free loans by the President during and The amounts are as follows:
Customer Withdrawal
Total Loan
The 'loans' were explained as funds borrowed from the account by president of the organization. Based on public record research, the loans were for some type of down payment for non-exempt property purchase(s) owned by / to be used as rental, office space or apartments.
Total expenditures during were$ (including loans) The expenditures conducted by were similar to expenditures.
(debit cards ending
Items worth noting include:
ATM cash withdrawals conducted at various and totaling -$ The withdrawals were classified as "transportation assistance" on G/L which was provided in response to IDR 2.
Dining, buffets, Fast food purchases, etc. totaling$ Groceries totaling$ Total debit card and expenditures - $ 14 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer
The expenditures conducted by
Tax Identification Number
(debit card ending ) were
Items worth noting include: similar to expenditures.
ATM cash withdrawals conducted at various Withdrawals at casinos totaling$ totaling ATM Dining and fast-food purchases totaling$ Groceries totaling$ Other expenditures ) totaled$ Total Debit card expenditures $ Checks and other Debits were written to The following checks totaling$ payments':
Date Check# Amt
$
$
Checks and were written by for 'rent memo "Rent payment"
"rent from to as the payee. Check and was purportedly for end of the stated that" is Trust. The trust does not have an EIN" year rent for In response to IDR 5, and is and IDR 1 response reported that$ in occupancy/ Note that Form rental expenses would be paid by the Other transfers and payments to include:
Date Check# Amount
$
Transfer
$
$
% owned by and flow-corporations owns Memo Check Signer Blank Charitable Assistance in 15 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number $ Repayment Of Travel Expense to for date response to IDR 5 stated check was a "loan to that has since been reconciled on previously requested documents"; check number "withdrew check for$ for donation to different charitable organizations in but only needed to send$ . Deposited$ back in account"; check number "repayment of ticket expense to for ticket bought from account for activities of Summary of the transfers and check payments to No contemporaneous substantiation has been provided to prove debit card purchases or checks and transfers to served a charitable or tax-exempt purpose.
The remainder of
Date Check #
'other' expenditures include:
Amount
$
$
$
$
$
$
$
Payee
16
Memo repair
Properties
Assistance
With Funeral
Expense for
Transport
Of Illegible
To picnic on
Check Signer hrs.
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Total Other Expenses response to IDR 5 stated check was for "assistance with handyman services to purchase and repair damaged residence for people who could not afford it especially in the summer"; checks through were accounting fees for books and tax return preparations; check was "to assist family going through significan [sic] difficulties with funeral expenses"; check was" day ( hrs.) payment for driver to transport people to location picnic and back home".
No contemporaneous substantiation has been provided to assert the Other expenses served a charitable or tax-exempt purpose.
Total expenditures:
Debit Cards (
Transfers and check payments to Other Expenditures
Total
The
Include: expenditures conducted by
ATM cash withdrawals conducted at various Buffet dining at Other Expenses$ Total$ totaling$ $ $ (debit card ending totaling$ The expenditures conducted by similar to & expenditures.
(debit card ending
Items worth noting include:
ATM cash withdrawals conducted at various Withdrawals at casinos totaling$ Dining and fast-food purchases totaling$ Groceries totaling$ 17 totaling ATM ) were
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Travel totaling$ Other debits$ storage shed) (Internet and cable tv, furniture, insurance payment, DMV, Total debits from card ending $ These expenditures remain unexplained and unsubstantiated.
Other debits payable to include:
Check number to dated totaling$ was written by as the payee which stated in the memo "amount owed after account reconciliation". has not provided contemporaneous substantiation or documentation to prove this this expenditure served an exempt purpose.
On conducted a bank teller withdrawal totaling$ Per minutes provided by the cash withdrawal was for a purported project. The minutes discussed a" to assist with their construction project for orphans as well as provide food, total cost is $ representatives of the organization will be present at these orphanages during to , after a brief discussion the board agreed". has not provided contemporaneous substantiation or documentation to prove this this expenditure served an exempt purpose. Rather, provided vague and generic donor acknowledgement letters dated & from"
"a purported overseas entity. These letters were dated months before the$ cash withdrawals. provided no other substantive information. The required information must include specific accounting, contemporaneous receipts, invoices & photo evidence, correspondence between parties of the transactions, documents detailing of what type of assistance was given and how much, to whom the grants were given (including contact information), whether the recipient is a qualified charity or member of a charitable class, follow-up grant reports, and other explanations (who, what, when, where, why, how?) Furthermore, the donor 'acknowledgement' letters do not name as the donor the donor.
Other unsubstantiated transfers to on totaling$ A bank teller withdrawal on Unsubstantiated Checks include: include a bank transfer (Acct ending ) totaling$ Checks written to totaling$ for bookkeeping/return preparation. has not provided documentation that the bookkeeping expenditures were solely for or whether the payments included bookkeeping fees for other owned businesses.
18
Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer
Other unsubstantiated checks include: amt check# payee
Date
$
$
$
$
$
$
$
Total
$
$
Total Expenditures:
Debit Cards
Transfers and check payments to Bookkeeping Other Expenditures Audit representation
Total
Note the other expenditures above ($ payable to Tax Identification Number memo Feeding the Feed the Feeding ... (illegible) repayment for ... illegible) Legal Representation $ $ $ $ $ includes check number for$ on mother, board member and disqualified This expenditure also remains unsubstantiated. person The only expenditure that was verifiable was the$ representation. expenditures conducted by The Include:
ATM cash withdrawal totaling$ $ Total$ payment for audit (debit card ending 19
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number The expenditures conducted by similar to , & expenditures.
(debit card ending
Items worth noting include:
ATM cash withdrawals conducted at various locations totaling$ Dining and fast-food purchases totaling$ Groceries totaling$ Other debits$ Total debits from card ending $ These expenditures remain unexplained and unsubstantiated.
Other debits payable to include:
Check number dated totaling$ was written by ) were to as the payee which stated in the memo "sponsoring different food services for indigents has not provided contemporaneous substantiation or documentation to prove this this expenditure served an exempt purpose.
On conducted a bank teller withdrawal totaling $ Per minutes provided by the cash withdrawal was for a purported project. The minutes alluded to a$ donation "to assist individuals and families in during this pandemic." has not provided contemporaneous substantiation or documentation to prove this this expenditure served an exempt purpose. and transfers from the below.
Wire Transfers to
Date
TOTAL mother,
Amount account to ) also initiated several wire , as seen Desription meeting minutes for made reference to the purchase of property for approximately$ "to erect a structure that can be allocated to families in need for a specific period ( months) "The minutes also hinted at another loan from , president of 20 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number No information was submitted that included specific accounting, contemporaneous receipts, invoices & photo evidence, correspondence between parties of the transactions, documents detailing of what type of assistance was given and how much, to whom the grants were given (including contact information), whether the recipient is a qualified charity or member of a charitable class, follow-up grant reports, and other explanations (who, what, when, where, why, how?) Other unsubstantiated transfers to include a bank transfer on totaling $ (Acct # ending ) . A Customer "image" withdrawal on totaling$ Unsubstantiated Checks include: totaling$ for bookkeeping/return Checks written to preparation. were solely for has not provided documentation that the bookkeeping expenditures or if the payments included bookkeeping fees for other owned businesses.
Other unsubstantiated checks include:
Unsubstantiated Checks
DATE AMOUNT CHECK# PAYEE
TOTAL
Total Expenditures:
Debit Cards $
Transfers and check payments to Bookkeeping Wire Transfers Payroll Other Expenditures
Total
21
$
$
$
$
$
MEMO DESRIPTION
Feeding underpriveledged
House Supply of
Repayment of Expenses
Funeral Assistance During
Dealer Fees & Transportation
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number Note the other expenditures above ($ ) includes check number for on payable to mother, board member and disqualified person This expenditure also remains unsubstantiated.
The only verifiable expenditures were the$ payments for payroll.
Total expenditures
$ $ $ $ 2
Review of summonsed bank information for its initial short year
Total
$ ) and full year, bank accounts ( ), revealed 1~ transaction conducted was at , an all-you-can-eat buffet at the The transactions in and mirrored the exam years' transactions through See attached Exhibit B. received a donated van from a public entity and continues to solicit donations from the State of , Federal Surplus Program; The Department of Social Service in ; and

# Law

Section 501(c) (3) of the Internal Revenue Code provides for exemption from taxation for organizations "organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or to foster national or amateur athletic competition ... , or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual..."
Regulation Section 1. 501 (c) (3) -1 (c) (1) states that "An organization will be regarded as 'operated exclusively' for one or more exempt purposes only if it engages primarily in activities which accomplish one or more of such exempt purposes specified in section 501(c) (3). An organization will not be so regarded if more than an insubstantial part of its activities is not in furtherance of an exempt purpose."
Regulation Section 1.501(c) (3)-l(c) (2) Distribution of Earnings. - An organization is not operated exclusively for one or more exempt purposes if its net earnings inure in whole or in part to the benefit of private shareholders or individuals.
For the definition of the words private shareholder or individual, see paragraph(c) of § 1. 501 (a) -1.
Regulation Section 1.501(a)-l{c) Related Private Shareholder or Individual Defined.
The words private shareholder or individual in section 501 refer to persons having a personal and private interest in the activities of the organization.
8 Includes purported loans
22
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
Regulation Section 1. 501 (c) -1 (d) (1) (ii) states that "An organization is not organized or operated exclusively for one or more of the purposes specified unless it serves a public rather than a private interest. Thus, to meet the requirement of this subdivision, it is necessary for an organization to establish that it is not organized or operated for the benefit of private interests such as designated individuals, the creator or his family, shareholders of the organization, or persons controlled, directly or indirectly, by such private interests."
Section 4958(f) of the Internal Revenue Code - Other definitions

(1) Disqualified person
The term "disqualified person" means, with respect to any transaction-
(A)any person who was, at any time during the 5-year period ending on the date of such transaction, in a position to exercise substantial influence over the affairs of the organization, (B)a member of the family of an individual described in subparagraph (A), (C)a 35-percent controlled entity, (D)any person who is described in subparagraph (A), (B), or (C) with respect to an organization described in section 509(a) (3) and organized and operated exclusively for the benefit of, to perform the functions of, or to carry out the purposes of the applicable tax-exempt organization, (E)which involves a donor advised fund (as defined in section 4966(d) (2)), any person who is described in paragraph (7) with respect to such donor advised fund (as so defined), and (F)which involves a sponsoring organization (as defined in section 4966(d) (1)), any person who is described in paragraph (8) with respect to such sponsoring organization (as so defined).

(2) Organization manager
The term "organization manager" means, with respect to any applicable tax-exempt organization, any officer, director, or trustee of such organization (or any individual having powers or responsibilities similar to those of officers, directors, or trustees of the organization).
Regulation Section 1.6033-2 (i) (2) provides that "Every organization which is exempt from tax, whether or not it is required to file an annual information return shall submit such additional information as may be required by the Internal Revenue Service for the purpose in inquiring into its exempt status and administering the provisions of subchapter F (section 501 and following), chapter 1 of subtitle A of the Code … "
23
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
Rev. Rul 59-95, An organization previously held exempt from Federal income tax was requested to produce a financial statement as of the end of the year and a statement of its operations during such year. However, its records were so incomplete that it was unable to furnish such statements. Section 6033 of the Internal Revenue Code of 1954 provides that every organization, except as provided therein, exempt from taxation under section 501(a) of the Code shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and shall keep such records, render under oath such statements, make such other returns and comply with such rules and regulations as the Secretary of the Treasury or his delegate may from time to time prescribe. Held, failure or inability to file the required information return or otherwise to comply with the provision of section 6033 of the Code and the regulations which implement it, may result in the termination of the exempt status of an organization previously held exempt, on the grounds that the organization has not established that it is observing the conditions required for the continuation of an exempt status.
Rev. Rul. 56-304, Organizations privately established and funded as charitable foundations which are organized and actively operated to carry on one or more of the purposes specified in section 501(c) (3) of the Internal Revenue Code of 1954, and which otherwise meet the requirements for exemption from Federal income tax are not precluded from making distributions of their funds to individuals, provided such distributions are made on a true charitable basis in furtherance of the purposes for which they are organized. However, organizations of this character which make such distributions should maintain adequate records and case histories to show the name and address of each recipient of aid; the amount distributed to each; the purpose for which the aid was given; the manner in which the recipient was selected and the relationship, if any, between the recipient and (1) members, officers, or trustees of the organization, (2) a grantor or substantial contributor to the organization or a member of the family of either, and (3) a corporation controlled by a grantor or substantial contributor, in order that any or all distributions made to individuals can be substantiated upon request by the Internal Revenue Service.
In John Marshall Law School v. U.S., 81-2 U.S.T.C. 9514 (Ct. Cl. 1981), in which the Court found that the Commissioner acted properly in revoking exemption under IRC 501(c) (3) on the grounds of inurement to the controlling officers and their families. The inurement included, but was not limited to, payments to the families as follows: automobile, education and travel expenses, insurance policies, basketball and hockey tickets, membership in a private eating establishment, membership in a health spa, interest-free loans, home repairs, personal household furnishings and appliances, and golfing equipment.
Better Business Bureau v. United States, 316 U.S. 279 (1945), holds that the existence of a single non-exempt purpose, if substantial in nature, will destroy the exemption under section 501(c) (3). An organization will be regarded as operated exclusively for one or more exempt purposes only if it engages primarily in activities that accomplish one or more of such purposes.
24
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
In 63-1 USTC 19200, Cleveland Chiropractic College, a Corporation, Petitioner v.
Commissioner of Internal Revenue, Respondent, --, (Jan. 17, 1963) Affirming Tax
Court, 21 TCM 1, Dec. 25,299(M), T. C. Memo. 1962-1 [1939 Code Sec. 101(6)--similar to 1954 Code Sec. 501]--The court found: "A college was not entitled to exemption from corporate income tax for 1948-1951 where part of the net earnings of the college was found to have inured to the benefit of one of its trustees through payment of his personal expenses."
In 60-1 USTC 19371, Birmingham Business College, Inc.; John Ike Griffith; Hulon A.
Spears and Audrey Spears; Carl B. Carter and Jewell Carter, and Jewell Carter,
Petitioners v. Commissioner of Internal Revenue, Respondent (Apr. 04, 1960);
The court found that: "Taxpayer, an incorporated business college owned and operated by a brother and two sisters, was not a tax-exempt educational ...
Substantial portions of its net earnings were distributed to its owner-operators for their personal benefit."
IRC 6652

(c) Returns by exempt organizations and by certain trusts

(1) Annual returns under section 6033(a) (1) or 6012(a) (6)

(A) Penalty on organization. In the case of-

(i) a failure to file a return required under section 6033 (a) (1)
(relating to returns by exempt organizations) or section 6012(a) (6)
(relating to returns by political organizations) on the date and in the manner prescribed therefor (determined with regard to any extension of time for filing), or

(ii) a failure to include any of the information required to be shown on a return filed under section 6033 (a) (1) or section 6012 (a) (6) or to show the correct information, there shall be paid by the exempt organization $20 for each day during which such failure continues. The maximum penalty under this subparagraph on failures with respect to any 1 return shall not exceed the lesser of $10,000 or 5 percent of the gross receipts of the organization for the year. In the case of an organization having gross receipts exceeding $1,000,000 for any year, with respect to the return required under section 6033(a) (1) or section 6012(a) (6) for such year, in applying the first sentence of this subparagraph, the amount of the penalty for each day during which a failure continues shall be $100 in lieu of the amount otherwise specified, and, in lieu of applying the second sentence of this subparagraph, the maximum penalty under this subparagraph shall not exceed $50,000.
Government's Position:
25
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number failed the operational test of IRC
501 (c) (3) on the following grounds:

(1) Inurement of the organization's income and assets
Disqualified Persons and are disqualified persons with respect to
Both are organizational managers that possess signature authority and debit cards over bank account; and control the affairs and are also disqualified persons, as they serve on board of directors, which constitute organizational managers. They were also able to exercise substantial influence over the affairs of the organization. is also a disqualified person by being a family member (Ancestor) to earnings inured to the benefit of its disqualified persons and private shareholders and operates to fund their gambling habits, personal entertainment, buffets, travels, and other personal purposes.
Analysis of the bank records reveals the total economic benefit provided to by was$ during the -year period. These expenditures were personal in nature and did not serve any exempt purpose and constitute inurement:
ATM W/D
Daily meals
Entertainment
Purchased Other
$
$
$
$
$ , Groceries etc.
Total
$
$
$
__
$
$
$
$
$
__
$
$
$
$
$
Total
$
$
$
$
$
$
The total economic benefit provided to by was$ during the -year period (inclusion of the year to capture forgiven loan).
These expenditures were personal in nature and did not serve any exempt purpose:
26
Form 886-A
Name of taxpayer
ATM W/D
Daily meals
Travel
$
$
$
Purchased Other , Groceries etc.
Total
$
EXPLANATIONS OF ITEMS
$
$
$
$
$
Tax Identification Number
$
$
$
$
__
$
$
$
$
$
_$
$
Total
$
$
$
$
$
_$
Checks, transfers and other debits for the benefit of limited to: include but not : check numbers cleaning totaling$ totaling$ unexplained checks deemed , and for property maintenance, repairs and a teller withdrawal totaling$ ; Check numbers for bookkeeping/ return preparation; miscellaneous personal & totaling$ check number totaling $ totaling$ for property repairs; check numbers and check numbers distributions of for purported rent payments; online banking transfer & consisting of unsubstantiated payments/ funds to totaling$ , check numbers totaling$ for bookkeeping/ return preparation; unexplained and unsubstantiated checks & totaling$ Teller cash withdrawals totaling$ online bank transfers totaling $ ; check numbers totaling$ for bookkeeping/ return preparation; unexplained checks totaling$ ; Check number totaling$ consisting of a distribution to : Teller cash withdrawals totaling$ , online bank transfers to account# ending , totaling$ ; wire transfers to , totaling $ ; check numbers , totaling$ for bookkeeping/ return preparation; withdrawals and checks, numbers , totaling $ for cable/internet; unexplained checks totaling $ ; Check number totaling$ consisting of a distribution to Total Benefits to which constitute inurement:
27
Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
Total
$ $ $ $
The Combined economic benefit provided to 's disqualified persons totals
$ ( , includes loan forgiveness).
The organization's total expenditures (including loans issued) for through was$ The only verifiable expenditures were professional/ legal fees paid to current representative, the / , totaling $ , and payroll amounts (Total$ ) to and The total inurement of income and assets by the disqualified persons' equals ic % during and received improper economic benefits from transactions over the course of , & They used funds for personal purposes unrelated to furthering an exempt purpose. The expenditures were not remuneration for the performance of services as the exam concluded that did not conduct any activities. Furthermore, did not file any Forms W-2 or 1099- Miscellaneous. reported on both Forms and that no compensation would be paid to the disqualified persons. There is no other evidence, contracts, agreements or claims to suggest these expenditures were consideration for the performance of services.
In addition to the gambling & entertainment, buffets, travel, groceries, transfers and dividend type distributions, loan forgiveness, and other personal items, the inurement includes checks written to family members - disqualified persons for repairs of personal and business properties. does not own any property, nor does it engage in any activity that would warrant such expenditures.
The bank transfers and dividend type distributions conducted in and are not loans or payments for charitable endeavors. For instance, the $ check written to clearly stated these funds were owed to as the check memo stated, "amount owed after account reconciliation".
Furthermore, the and cash withdrawals totaling$ and$ respectively, nor the wire transfers totaling$ to the during , constitute charitable expenditures as the exam concluded the is a sham organization conducting no charitable activity. has not provided contemporaneous substantiation or sufficient documentation to show these expenditures served an exempt purpose. provided no evidence that it exercised any expenditure responsibility regarding these purported foreign charitable grants. did provide board approval minutes and generic donor acknowledgement letters from" ", or any other source. The 9 Includes Loan Forgiveness of$ 10 [ $ _ $ $ l $ 28 I $ % Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number acknowledgement letters submitted, fail the substantiation requirements based on the following information:
The letters were dated and months before the
$ withdrawals occurred.
The letters do not specify as the donor the donor.
The letters do not specify what was given and how, why and when did not provide expenditure responsibility or other substantiation, such as line-by-line accounting, contemporaneous receipts, invoices & photo evidence, descriptions of the type of assistance given, to whom, evidence that the recipients are of a charitable class or is a qualified charitable organization.
Board of Directors are 'in name only' because the Board is complacent and does not exercise fiduciary care because they allowed and failed to prevent the inurement of assets by and The board also failed to compel accounting and expense authorization from and Furthermore, the Board of Directors also participates in the inurement of assets, as of board members received unsubstantiated payments from during the exam period that was not reported on Forms The$ cash withdrawals conducted by constitute inurement of income and assets, and the acknowledgement letters and board approval are false attempts to legitimize the inurement.
The inurement of income and assets is exacerbated further by the fact that has attempted to pass off these personal expenditures as legitimate expenses; aimed at serving purported mission to clothe and feed the has not provided substantiation that the bookkeeping and return preparation were exclusively for as opposed to his personal for-profit entities. As a result, bookkeeping and tax return preparation expenditures are also deemed personal.
The Revenue Agent attempted to get further clarification from as to how its expenditures, which appeared highly personal in nature, served to further tax-exempt purposes. responses ranged from wholly unbelievable to obstructionist. For example, in one response, claimed that the numerous cash withdrawals and conducted at casinos were for "yard sales". In a separate response to the Revenue Agent's requests for detailed information on the patients that helped support, the organization simply replied, "Absolutely not." paid$ in 'rent' expense during , yet rental agreement 11 stating and Forms reported$ in occupancy that it only operates to serve 11 In initial IDR 1 response for the year. would not charge expenditures. The and 29 inexplicably produced a rent. Form exam of concludes and does not engage
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number in any activity to support the rental expense paid by to is a valid expense. The rent expense is an improper payment and constitutes inurement.
The.disqualified persons siphoned nearly % of funds for the years , &
• This constitutes inurement and is explicitly prohibited in IRC Code
Section 1. 501 (c) (3) -1 (c) (2), Distribution of Earnings. operated like the organizations described in and Better Business Bureau. Those organizations were revoked due to inurement in the form of various improper payments to the controlling officers and their families.
The continued and constant inurement of assets demonstrate that there is no accountability, internal controls or safeguards in place to protect assets.
There is no independent board oversight preventing the commingling and inurement of the organization's funds and assets. The board of directors is comprised of all family members who also participate in the inurement (to a lesser degree).

(2) has not engaged in any exempt activity during its entire existence. expenditure incurred was in , which was a$ expenditure at the in for an all-you-can eat buffet located in the transactions from through mirrored the inurement transactions of The Internal Revenue Service requested that the organization provide specific information about its activities during the years ending , & has refused to provide information on its charitable activity and has refused to show its transactions served an exclusive charitable purpose. will not identified any individuals it purportedly assisted, nor will it describe a selection process used to screen and award a potential candidate. did not provided verification documents, or organizational policies describing its selection process. does have a website to advertise its services and is not located or referenced in any online directory as a provider assistance. attempted to circumvent the substantiation requirement by falsely claiming it is a HIPAA covered entity subject to HIPAA's disclosure and confidentiality rules.
However, is not a covered healthcare provided under HIPAA because it does not furnish, bill, or receive payment for healthcare, nor does it transmit (send) any covered transactions electronically in the normal course of business. More importantly, has not satisfied the record keeping requirements of Rev. Rul.
56-304.
As required by Revenue Ruling 56-304, the organization did not provide any records to show that it continues to operate for exempt purposes; and has failed to comply with the provision of section 6033 of the Code. An exempt organization must respond to Internal Revenue Service inquiries to establish that it is entitled to tax exempt status. In this case, the organization did not provide adequate records to show it was operated exclusively for exempt purposes. The primary position 30 Form 886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number outlined above further demonstrates that the organization's assets inured to its private shareholder.
Despite not conducting any charitable activity and transferring exclusively all of its assets to and as president of the continues to solicit donations from the State of falsely claiming the is engaged in charitable activity; The in and has operated as a sham charity since inception.
Penalties under 6652 (c) (1) (A) (ii)
Part III, Statement of Program Service Accomplishments reported its primary exempt purpose was to "provide crucial resources to the elderly, disable and displaced persons in our local community and in Such crucial resources are foods [sic], clothing, and transportation assistance to doctor's visits reported on Line 28 and Line 4 (Form that it provided food and clothing to over people in both and in $ I $ $ & $ for the respective , and years.
Line 29 reported that provided transportation assistance for doctor's visits - blank ( ) , $ & $ for the respective and years.
Line 30 reported that provided medical equipment to the sicks [sic] - and did not quantify the amounts. attached Schedule 0, Supplemental information, to its and Form which listed the following "other" expenditure explanations and its "other asset":
31
Form886-A
Name of taxpayer
Forms & Form
Schedule O Information
Transportation
Bank Fee
Feeding & Clothing in and
Liabbility Insurance
Promotion
Utilities
Receivable Loan
Amended
Accounting Fees
Auto Expenses
Benevolence
Transportation Assistance
Bank Charges
Feeding & Clothing
Insurance
License and Permits
Volunteers Meals and Snacks
Maintenance and Repair
Office Su pp lies
Postage and Shipping
Rent
Supplies
Telephone Exp
Travel
Utilities
Receivable Loan
EXPLANATIONS OF ITEMS
Tax Identification Number
Accounting Fees
Auto Expenses
Benevolence
Bank Charges
Feeding & Clothing
Insurance
Maintenance and Repair
Office Supplies
Postage and Shipping
Rent
Supplies
Travel
Transportation Assistance
License and Permits
Receivable Loan
Foreign Mission Exp
Insurance Expense
Postage & Shipping
Profession I & Legal Services
Sipplies Expense
Other Expenses & Fees & Pern
Telephone expense
Utilities
32
Form886-A EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
This reporting on the Form is false. None of activities or expenditures during , and served a tax-exempt purpose, rather, its income and assets inured to the benefit of the insiders and
Part IV, Officers Directors, Trustees, Key Employees
The organization reported the governing body as follows:
Name Average hrs. per wk. , President , Secretary/
Treasurer , Director , Director , Director
Compensation
$
$
$
$
$
This reporting on the Form is False. The total benefit provided by the organization to the disqualified persons was substantial and included payroll ( ) to of$ during the -year exam period.
Part VI, Other Information checked negatively "No" to the following questions:
Line 33, "did the organization engage in any significant activity not previously reported to the IRS? If Yes, provide a detailed description of each activity in Schedule 0."
This reporting is false because did not disclose to the Service that it exclusively served the benefit of the founders.
Line 38 (a) asked, "did the organization borrow from, or make any loans to, any officer director, trusted, or key employed or were any such loans made in a prior year and still outstanding at the end of the tax year covered by this return? (b) if yes, complete Schedule L, Part II and enter the total amount involved."
Schedule L was not attached to the Forms
33
Form886-A
EXPLANATIONS OF ITEMS
Name of taxpayer Tax Identification Number
Line 40 (b) asked "Did the organization engage in any section 4958 transaction during the year, or did it engage in an excess benefit prior year that has not been reported on any of its prior Forms yes, complete Schedule L, Part I." excess benefit transaction in a or ?
If
This reporting is false because the exam determined that did engage in excess benefit transactions under 4958 during all years with its disqualified persons.
Schedule I was not attached to the Forms , or Form for
Taxpayer's Position:
The organization has not submitted its position.

# Conclusion

Revocation of tax-exempt status under 501(c) (3) is proposed because (1) the assets inured to the organization's disqualified persons and and (2) has not conducted any charitable or exempt activity (since inception) and failed to failure to provide records to the Service regarding its expenditures. Exemption under Code section 501(c) (3) for should be revoked retroactively effective The organization is required to file Forms for all taxable years. has failed to show the correct information on its Forms or Form , as required by section 6033(a) (1) for the years ending through The organization has not established reasonable cause and is therefore liable for penalties described under IRC Sec. 6652 (c) (1) (A) (ii). The penalty prescribed by §6652 (c) of $ per day will be utilized for computational purposes as the organization has received less than $ in gross receipts during each of the years.
Forms & Form
Gross Receipts $ $ $ $
Due Date
Days12
Rate$ per day $ $ $ $
Penalties $ $ $ $
Total
~
12 Report date
34
Exhibit A
DESCRIPTION OF SERVICES BY THE
We are well aware that has a and crisls. These people are left to live in the streets, sleeping on street side walks and park benches while the gov«runent continues to scramble for solution for many years.
Since, its establishment in • have·partnered with many hospital discharge p1anners and owners of independent living houses especially in and These independent living houses independently may house to individuals and or families for a short time following hospital dlsoruirge, preventin& them from being discharged to a shelter. There are at least independent living houses operating in and they have sheltered over people since • While shelter is provided, these house owners are not always able to meet the needs of these individuals and requires assistanoe from organizations sueh as the to provide meals and assistance to individuals until they are able to secure their own housinSt transportation and financing. Here are a few addresses that have bee1r supported by our organization since
• • • • • • • •
•
• • • • • •
1
Exhibit A
• • •
•
• • •
•
•
•
•
•
• • • •
• • •
• • • • • • • • •
•
Explanation of how decide to help:
Board members of have a relationship with the cotmnunity house owners and managers who identify independent living homes in the community. K.nown to our organiza.tio~ independent living homes houses people of low income as well as no income. Due to this income deficiency, multiple adults share a living $pace 2 Exhibit A so they can share the expenses and this leaves them little or nothing to survive on. will provide these individuals food, transportation and sometimes pay a small fee for individuals to al.l~w them to reside in certain homes for a short pel'iod of time until their financial restrictions are lifted.
Crlteria for Helping those in Need:
· Before individuals ate accepted into independent living houses, their incomes are verified by hospital case managers as well as house owners and managers. Keep in mind that the average monthly payment by the state of for persons are $ which they are expected to pay for housing, food and maintenance.
3
1
Debit Card Ending descriQtion amount
$
$
$
$ $ date
11
Year Ending
Transfer to savings
Debit Card Ending description
ATMW/D amount account
$
$
$
$
Exhibit B date
L
DR(
W/D-
W/d-
W/D-
$
$ $ $
$ $ $
$ $
$ $ $ $
2
$
$
$ $ l I I ) 11

(loan)
TLR w/d (loan)
Service Fees service fees
( (
DR(
TLR w/d w/d-
W/D-
W/D-
W/D- W/D- W/D-
$
$
$
$
$ $ $
$
$ $ $
$
$
$ $
$
$
W/D-
$ $ $
$ $ $
$
$
$ $
$
$ $ $ al ...,
1:i .s:::.
X w
'V). 'V).
V,
Q)
Q) u..
Q) u -~
Q)
V)
'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V). 'V).
4 service fees
$
$
$
$
11
Service Fee
W/D-
W/D-
W/D- W/D-
W/D-
W/D- W/D-
$
$
$
$
$
$ $ $ $
$ $
$
$
$ $
$
$
5
$
$ $
$
$ $ $
$
$ $
$
I I
Service Fees Service Fees
W/D-
W/D- W/D-
$
$
$
$ $
$
$
$
$ $
$
$ $
$
$
$
$
I I
Service Fees W/D
$
W/D- W/D-
$
$
$
$
$
$ $
Total
Balance
Debit Card#
Memo
- Checking Opening Deposit ) )
Interest Payment
(
Payee
Short Year Ending
Debit
$
$
$
$
Check
- Interest Payment
W/D
W/D W/D
$
$
$ $
$
Credit
Account
$
$
Date
$
$
$
$ $
Grand Total $ Total Expenditures including loans
Less Loans Issued
Less Tax Law Center
-$
Plus Loan Forgiveness total benefits
$
%

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