Amend16RobertWirengard v. Commissioner

T.C. Memo 2005-30 (2005)

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Amend16RobertWirengard v. Commissioner

United States Tax Court
T.C. Memo 2005-30 (2005)

Facts

Amend16RobertWirengard (Amend16) (plaintiff) applied for exemption from federal income taxation under § 501(c)(3) of the Internal Revenue Code (code). The application described Amend16 as a free Internet school offering financial-education services. Amend16’s articles of organization stated that it was organized for charitable purposes, including the provision of economic and financial education and other assistance to low-income individuals. Amend16’s bylaws created five divisions for the organization, one of which was United Bank. According to Amend16’s website, United Bank would provide banking products and services to individuals and businesses, including microloans intended to help low-income individuals. A sample note for such a microloan provided for a 6 percent interest rate. United Bank was neither incorporated nor a member of the Federal Deposit Insurance Corporation (FDIC). The commissioner of internal revenue (commissioner) (defendant) found that United Bank did not further an exempt purpose and denied Amend16’s application. Amend16 then sought declaratory relief to the effect that it was entitled to the tax exemption.

Rule of Law

Issue

Holding and Reasoning (Wells, J.)

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