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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. Karl
H. Goesele attended a seminar presented by Mr. Tully, and Mr.
Goesele retained Mr. Tully to organize a tax-exempt foundation
for Mr. Goesele. Mr. Tully organized a corporation named "Share
Network Foundation" (petitioner herein). Petitioner's officers
are Mr. Tully (vice president), Mr. Goesele (president and
treasurer), Michael D. Tate (vice president), Sylvia A. Goesele
(secretary), and Ven. N. Kunga Gyaltsen (secretary). Karl H.
Goesele is Sylvia A. Goesele's father, and Ms. Goesele is Mr.
Tate's wife. Messrs. Goesele, Tate, and 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 AND MAINTAIN A PHYSICAL FACILITY FOR SPIRITAL
[sic] WORSHIP." The bylaws state that petitioner's primary
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