Tamaki Foundation - Page 11




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          Christian Echoes Natl. Ministry, Inc. v. United States, 470 F.2d            
          849, 857 (10th Cir. 1972).                                                  
               We have previously observed that the opportunity for abuse             
          is present when the affairs of an organization are controlled by            
          its creators who belong to the same family.  See Bubbling Well              
          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            







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