- 3 - Deductions claimed by petitioner in 1989 and 1990 produced net operating losses (NOL’s) of $55,918 and $26,854, respectively, which petitioner carried forward to 1991. Similarly, petitioner claimed deductions in 1992 that resulted in an NOL of $4,957, and petitioner carried forward the NOL to 1993. Respondent disallowed the deductions as in excess of fair market royalties for the licensed assets. Petitioner reported taxable income for the taxable years in issue of: Year Taxable Income 1991 $200,338 1992 (4,957) 1993 115,160 Petitioner was incorporated in June 1987 as a nonprofit mutual benefit corporation under the nonprofit mutual benefit corporation law of the State of California. Cal. Corp. Code sec. 7110 (West 1990). It is a taxable subchapter C corporation for Federal income tax purposes but has not issued any capital stock. Petitioner's profits are to be used for a common purpose of its members, who do not personally benefit from its profits. Petitioner's articles of incorporation provide that petitioner was formed "to contribute financially and in other ways to the activities and welfare of non-profit organizations dedicated to the transmission and preservation of the Buddha Dharma". Despite petitioner's stated purpose, petitioner has not made a charitable contribution to a Buddhist organization since its inception. A secondary purpose of petitioner is to provide a work environment in which to practice Buddhist principles.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011