- 8 -
virtually identical to the administrative record at hand. See
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 also 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.
We apply the reasoning of those cases and hold that
petitioner fails to qualify for exempt status under section
501(c)(3). Accordingly,
Decision will be entered
for respondent.
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Last modified: May 25, 2011