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transmit Buddhist teachings in the West, and to provide a work
setting in which to practice Buddhist teachings. DM was a
section 501(c)(3) organization for Federal tax purposes from
December 1, 1987 to November 30, 1992. From its inception in
1975 to 1985, DM was also engaged in the commercial printing
business. In 1985, employees of DM who were members of the
Nyingma community formed Skillful Means Enterprises, also known
as Skillful Means Press (SMP), to take over DM's commercial
printing business, and DM ceased its commercial printing
operations. Most of SMP's employees were members of the Nyingma
community. DM provided a startup loan and rented printing
equipment and building facilities to SMP. DM intended that SMP
would not own any assets. DM also licensed the right to use
certain intangible assets, including the name "skillful means",
to SMP in exchange for royalties.
A member of the Nyingma community, Arnaud Maitland
(Maitland), formed petitioner in June 1987 to provide binding
services to SMP. Maitland earned a master’s degree from the
Nyingma Institute and served as its dean from 1980 to spring
1987, first at its Boulder campus and then in Berkeley. Maitland
has taught classes at the Nyingma Institute, including classes in
skillful means. He lived at the Nyingma Institute for rent of
$200 per month. Maitland was petitioner's chief executive
officer.
One month after petitioner's incorporation, in July 1987, DM
notified SMP that its license and rental agreements would
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Last modified: May 25, 2011