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of $1,554,244 in 1998 and anticipated gifts, grants, and
contributions of $5,000 per year for 1999 and 2000. The
statement further projected for both 1999 and 2000 gross
investment income of $120,454 and an annuity obligation of
$116,568. The resultant excess of revenue over expenses for 1999
and 2000 was therefore a projected $8,886 ($3,886 + $5,000),
respectively. The $1,554,244 note receivable was shown on the
attached balance sheet as petitioner’s sole asset.
During the administrative process, petitioner also
represented that: (1) Petitioner would receive outright
testamentary gifts of approximately $693,000 at the death of the
Laphams through beneficiary designations of retirement assets;
(2) petitioner would be the beneficiary of a charitable lead
trust under the revocable living trusts of the Laphams which,
based upon certain assumptions, would distribute $355,834
annually to petitioner for a period of 17 years from the Laphams’
deaths; and (3) the Laphams had pledged an additional $207,733 to
petitioner contingent on approval under section 501(c)(3) and
509(a)(3).
As regards petitioner’s support of AEF, the Form 1023
reflected that petitioner intended to pay at least 85 percent of
its income to the organization and anticipated a contribution
annually of approximately $7,600. Later, in correspondence
exchanged during administrative consideration, petitioner stated:
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Last modified: May 25, 2011