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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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