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Church of Universal Love, Inc. v. Commissioner, 74 T.C. 531, 535
(1980), affd. 670 F.2d 104 (9th Cir. 1981). In such a situation,
therefore, we require an open and candid disclosure of all facts
bearing upon the organization, its operations, and its finances
so that we may be assured that we are not sanctioning an abuse of
the revenue laws by granting a claimed exemption. See id.; see
also United Libertarian Fellowship, Inc. v. Commissioner, T.C.
Memo. 1993-116. Where such a disclosure is not made, the logical
inference is that the facts, if disclosed, would show that the
taxpayer fails to meet the requirements of section 501(c)(3).
See Bubbling Well Church of Universal Love, Inc. v. Commissioner,
supra at 535.
Petitioner leaves us no choice but to draw such an inference
here. The record is devoid of sufficient documentation or other
substantive information regarding petitioner's organization,
activities, or operations. What little information petitioner
did provide, pursuant to respondent's requests, was extremely
vague and, in our view, simply an attempt by petitioner to avoid
disclosing the requested information. Petitioner has completely
failed to establish its entitlement to tax-exempt status.
We also note that petitioner has failed to prosecute its
case properly.1 Petitioner failed to file a brief, as ordered by
1 Petitioner's representative, Mr. Tully, is no stranger to
(continued...)
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