Sandhill - Correspondence with IRS Regarding 501d Classification

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Tax Information Package - SH-TXP5 - Correspondence with IRS Regarding 501d Classification

Correspondence with IRS Regarding 501d Classification

Sandhill Farm, Inc.
Route 1, Box 10
Rutledge, MO 63563
December 11, 1983

Internal Revenue Service
Washington, D.C. 20224

Dear IRS:

This is a reply to your letter to us of December 6, 1983, in which you requested additional information before making a determination on our application for recognition of exemption under section 501(d) of the Internal Revenue Code of 1954. Our responses below are numbered to correspond with your questions.

1. a) One of the central features of our group is the common spiritual ground shared by
our members, as expressed in Sandhill Farm's Statement of Spirituality (a copy of which was contained in our origianl submission). Right livelihood is an extremely important moral value among us, and we are anxious to share with others the joys and growthfulness that we have experienced in pursuit of this value.

There is an attempt among us to recognixe the spirituality in all that we do, and
there are certain ritual times when there is a particular focusing on this spirituality. For example, every day at the evening meal we hold hands and join in a moment o of silence. Also, the land is very important to us and respect for it is a major part of our ethic; we tend to celebrate natural cycles with days of thanksgiving. And
there is a strong spiritual element present in the occasional groupbathing we do in
a sweat hut. Perhaps the two times in the community's history when the spiritual force was most strongly felt was at the home births fo the two children who have
lived here.

Sandhill Farm is an intentional community, and what we are intending is to create an entire lifestryle choice which is fundamentally different than those traditionally available in our culture.

b) Yes, members include their pro rata share of Sandhill Farm's income, whether
distributed or not, in their individual gross income each year.

2. See Attachment A.

3. For a breakdown of membership by class and year, see Attachment B. No one has
been employed full time outside of Sandhill Farm since the community became
incorporated in December, 1979. The community does do a certain amount of
short-term, part-time labor for various neighbors which might be construed as
outside employment, though we view this as employment of the community, not as employment of individual members. Nonetheless, following is a breakdown of such income by year:

Income for labor
for neighbors % of total income
1980 $3,534 66.5%
1981 $1,697 8.9%
1982 $1,457 11.6%

4. Yes.
5. Yes.

6. To date we have had three members become full members. Two did so after two years as provisional members, and the other after seven years (this last includes years before the community was formally structured as a legal entity).

7. The increase in donations in 1981 and 1982 is essentially attributable to a provisional member becoming a full member, and the increase in member loans is due to provisional members feeling more secure about the community and their place in it.

Farm income is down partly because of poor crop years, especially in 1982, and partly because with increases in other receipts we have been able and willing to devote more of our labor to non-income-producin work such as child care and construction of new facilities. As can be seen from our answer to question 3 above, our outside employment is down, not up, in recent years.

8. See Attachment C.

Under penalty of perjury, I have examined the responses above, including attachments, and to the best of my knowledge and belief they are true, correct, and complete.

Laird A. Schaub,