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After Ms. Spiegel deposited the money, she issued a check to
Reverend McWilliams in the same amount. Ms. Spiegel and Reverend
McWilliams were the only two people who had signatory authority
over the TFC account. Reverend McWilliams deposited the checks
into his personal account. Reverend McWilliams never provided
Agape with an accounting of how the funds were used.
Reverend McWilliams worked as Agape's minister. There was
no employment contract. Reverend McWilliams was hired as a
"private contractor". In addition to performing social work in
Mexico and working with deprived and disadvantaged people,
Reverend McWilliams performed baptisms and marriages. Reverend
McWilliams was neither a member of Agape, nor was he on Agape's
Board of Elders.
Reverend McWilliams was the president of TFC at the time TFC
temporarily closed its business in December 1988. Reverend
McWilliams also was in the business of providing food, shelter,
and medical care to various persons in a religious communal group
setting in exchange for payments. He reported profits from this
business.
During the taxable years at issue, petitioners and their
three children lived on the approximately 2-1/2 acre property
owned by Reverend McWilliams. Situated on the property is an
approximately 5,500 square foot building that served as living
quarters. The building consists of two wings and has a common
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Last modified: May 25, 2011