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Discussion
We must decide whether petitioner qualifies for exempt
status under section 501(c)(3). We have recently decided the
same issue adversely to six other entities formed and represented
by Mr. Tully, in cases with administrative records which were
virtually identical to the administrative record at hand. See
Hart Found. v. Commissioner, T.C. Memo. 1999-228; Resource
Management Found. v. Commissioner, T.C. Memo. 1999-224; Share
Network Found. v. Commissioner, T.C. Memo. 1999-216; Tamaki
Found. v. Commissioner, T.C. Memo. 1999-166; Tate Family Found.
v. Commissioner, T.C. Memo. 1999-165; Larry D. Bowen Family
Found. v. Commissioner, T.C. Memo. 1999-149. In each of those
cases, we held that the administrative record upon which the case
was to be decided did not contain enough evidence to support a
finding that the taxpayer met the operational test of section
1.501(c)(3)-1(c), Income Tax Regs. We noted that each of the
taxpayers had failed to prosecute its case properly, including
the fact that none of the taxpayers had filed a brief, as ordered
by the Court and required by Rule 151, or had explained its
failure to do so.
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