Attachment to IRS Form 1023

XXXXXXXXXXXX, Inc.
EIN: 22222222222
Part IV. Narrative Description of Your Activities


The Applicant was created by XXXXXXXXXX Church (a predominantly African American congregation located in XXXXXXXXXXXXX) for the express purpose of taking over two charitable and educational activities that are currently being operated by an exempt affiliate named XXXXXXXXXXX Development Corporation, Inc. The reason for doing this was to leave the affiliate better able to focus on operating a child care facility. The two activities will be transferred to the Applicant during the next tax year upon the expiration of the current funding contracts with XXXXXXXXX County and upon the renewal of those contracts into the name of the Applicant.

XXXXXXXX is an impoverished and physically deteriorated predominately African America neighborhood located directly north of downtown XXXXXXXX. It is characterized by extensive poverty, high levels of unemployment, deteriorated housing, and high crime. The young people that participate in the Applicant's activities are predominantly residents of XXXXXXXXX and adjacent low income neighborhoods.

Upon the transfer of the funding, the Applicant will have two administrative staff members, an "executive director" and an "assistant director".

Description of the Activities

Facilities.

XXXXXXXX County provides the Applicant with space for its activities at no charge. The space is located at the XXXXXX apartment complex which is a County owned, federally funded "public housing" project for low income tenants. Unit number 2035 is used for the After School Tutorial Program, the computer lab, and as the base for the Summer Day-Camp. Unit number 2043 is used by the Applicant for office space.

Conclusion:

The two above described activities further the Applicant's charitable and educational purposes. The regulations governing exemption eligibility for organizations described under section 501(c)(3) of the IRS Code are found at 26 CFR 1.501(c)(3)-1. The term "charitable" is defined in section 1.501(c)(3)-1(d)(2) to include "relief of the poor and distressed or of the underprivileged", "advancement of education" and "combating juvenile delinquency". The tutoring and summer day-camp programs of the Applicant further all three of those purposes. The term "educational is defined in Section 1.501(c)(3)-1(d)(3)(i)(a) which states that educational relates to the instruction or training of the individual for the purpose of improving or developing his capabilities or the instruction of the public on subjects useful to the individual and beneficial to the community. The activities of both the tutorial and day-camp programs meet that definition of "educational"