4
Evanescent Press has retained its letterhead and title, and its
income and expense was reported in John Stahl's personal income
tax return for the year 1993.
In September 1993, John Stahl deeded to petitioner the
Mendocino County property mentioned above, the Evanescent Press,
an automobile, and other miscellaneous property. Although
petitioner now owns the property, Mr. Stahl, his wife, and two
daughters (inter alia) continue to live there rent free; they
receive no salary from petitioner. All utilities, taxes, and
insurance on the Mendocino County property and the Evanescent
Press are now apparently paid by petitioner. As part of the
conveyance of the Mendocino County property to petitioner by Mr.
Stahl, petitioner assumed liabilities in the form of two
mortgages on the property, as well as assuming the burden of a
small amount of commercial credit advanced to the Evanescent
Press and some personal credit card debt of John Stahl himself.
Petitioner filed a Form 1023, Application for Recognition of
Exemption Under Section 501(c)(3), on October 12, 1992. The
application requested a ruling that petitioner was exempt from
tax under section 501(c)(3) and was other than a private
foundation under section 509(a)(1) because it qualified as a
church under section 170(b)(1)(A)(i). In the application, as a
statement of the "detailed narrative description of all the
activities of the organization--past, present, and planned",
petitioner stated as follows:
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