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section references are to the applicable versions of the Internal
Revenue Code. Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
We decide this case on the basis of the entire
administrative record, see Rule 217(b)(1), which is incorporated
herein by this reference. Petitioner's mailing address was in
Ontario, California, when its petition was filed.
William J. Tully is a promoter of tax-exempt entities. He
organized a corporation named "Resource Network Foundation"
(petitioner herein). Petitioner's officers are Mr. Tully (vice
president), David Lira (president), Salvador Lira (vice
president), Elizabeth A. Miller (secretary), and Marilyn Stewart
(vice president). David Lira, Salvador Lira, and Mr. Tully serve
as directors on petitioner's board.
Mr. Tully filed articles of incorporation for petitioner
with the Nevada secretary of state, and he prepared bylaws for
petitioner. The articles state that petitioner's primary purpose
is "To provide vocational enhancement programs." The bylaws
state that petitioner's primary purpose is that set forth in the
articles. The bylaws further state that "Nothing herein
contained shall be construed to prevent any Director from
receiving compensation for services to the Corporation rendered
in a capacity other than Director."
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Last modified: May 25, 2011