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principal thereof exclusively for religious purposes either
directly or by contributions to organizations that qualify as
exempt organizations under Section 501(c)(3) of the Internal
Revenue Code and its Regulations * * * ." During the taxable
years at issue, Agape was an organization described in sections
170(c)(2) and 501(c)(3) and listed in Publication 78. Agape was
located on property owned by Reverend Robert L. McWilliams
(Reverend McWilliams) in Brazito, New Mexico.
During 1991 and 1992, petitioners had canceled checks and
carbon copies of checks from their two personal checking accounts
on which they left the payee lines blank (blank checks). The
blank checks were deposited into a bank account (TFC account) of
Twenty-First Century Corporation (TFC) by Ms. Thelma Spiegel (Ms.
Spiegel). The record does not disclose the nature of TFC's trade
or business.
Ms. Spiegel, inter alia, served as the bookkeeper for Agape
during the taxable years at issue. She also had the authority to
make deposits to, and withdrawals from, the TFC account. Ms.
Spiegel was a member of Agape during the taxable years at issue.
Ms. Spiegel also collected and recorded the weekly contributions
from Agape's congregation. She deposited almost all of the
contributions into the TFC account. Agape did not have a
checking account in its own name.
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Last modified: May 25, 2011