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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.
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 purpose
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Last modified: May 25, 2011