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its creators. See Bubbling Well Church of Universal Love, Inc.
v. Commissioner, 74 T.C. 531, 535 (1980), affd. 670 F.2d 104 (9th
Cir. 1981). In such a situation, therefore, we require an open
and candid disclosure of all facts bearing upon the organization,
its operations, and its finances so that we may be assured that
we are not sanctioning an abuse of the revenue laws by granting a
claimed exemption. See id.; see also sec. 1.6033-2(h)(2), Income
Tax Regs. (an organization that is exempt from tax, whether or
not required to file an annual information return, must submit
any additional information that the Commissioner requires to
inquire into its exempt status). Where such a disclosure is not
made, the logical inference is that the facts, if disclosed,
would show that the taxpayer fails to meet the requirements of
section 501(c)(3). See Bubbling Well Church of Universal Love,
Inc. v. Commissioner, supra at 535.
Petitioner leaves us no choice but to draw such an inference
here. The record is devoid of sufficient documentation or other
substantive information regarding petitioner's organization,
activities, or operations. What little information petitioner
did provide, pursuant to respondent's requests, was extremely
vague and, in our view, simply an attempt by petitioner to avoid
disclosing the requested information. Petitioner has completely
failed to establish its entitlement to receive tax-exempt status.
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