- 2 - 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 primaryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011