- 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. Michael D. Tate and his wife, Sylvia A. Goesele Tate (collectively, the Tates), attended a seminar presented by Mr. Tully and retained him to organize a tax-exempt family foundation for them. Mr. Tully organized a corporation named "Tate Family Foundation" (petitioner herein). Petitioner's officers are Mr. Tully (vice president), Mr. Tate (president and treasurer), Ms. Goesele Tate (secretary), James O. Goethe (vice president), Karl H. Goesele (chief financial adviser), and Ann Villanueva (vice president). Karl H. Goesele is Ms. Goesele Tate's father, Ann Villanueva is Mr. Tate's mother, and James O. Goethe is a cousin of the Tates. Most, if not all, of petitioner's officers also serve as directors on its 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 purposePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011