-23- (2) Whether any of the following constituted an inurement of petitioner’s net earnings to an insider-- (a) diversions of bingo game proceeds, (b) amounts paid to attorneys Climaco and Zerbini, (c) a $2,500 check payable to the order of Ohio Boys Town, and (d) rental fees paid in connection with petitioner’s bingo games in the Center. A. Zeve, Popovic, or Vecchio as an Insider In order for an organization to qualify for exemption under section 501(c)(3), no part of the organization’s net earnings may inure to the benefit of any private shareholder or individual. Sec. 501(c)(3). A “private shareholder or individual” is broadly defined as any person having a personal and private interest in the activities of the organization. Sec. 1.501(a)-1(c), Income Tax Regs. Such private shareholders or individuals are sometimes referred to for convenience as “insiders”. See American Campaign Academy v. Commissioner, 92 T. C. at 1066; Sound Health Association v. Commissioner, 71 T.C. 158, 185-186 (1978). On opening brief respondent contends that Zeve, Popovic, and Vecchio were insiders with respect to petitioner. However, on answering brief respondent refers only to Zeve and Popovic. Petitioner contends that Zeve, Popovic, and Vecchio are not insiders with respect to petitioner.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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