Larry D. Bowen Family Found. - Page 11




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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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