- 10 -
specified that any director, except Mr. and Mrs. Lapham, could be
removed with or without cause by a majority vote of the directors
then in office.
In addition to the Laphams, the individuals named to
petitioner’s initial board of directors were John A. Gallina of
Northville, Michigan; Georgianna Chase of Northville, Michigan;
and Darcy Connolly of Cincinnati, Ohio. None of these three
directors had a family relationship with the Laphams, had an
employment relationship with the Laphams or any business owned by
the Laphams, or received a fee for services provided to the
Laphams. Mr. Gallina was appointed to petitioner’s board by AEF;
petitioner represented that Mr. Gallina also served on the boards
of directors of other organizations in southeastern Michigan
supporting AEF. Georgianna Chase was an elder of the First
Presbyterian Church of Northville, nominated by the congregation
and elected by general vote to the church’s governing body.
As correspondence passed between the parties during the
administrative process, respondent by letter dated April 19,
2000, recognized petitioner as exempt from taxation pursuant to
section 501(c)(3) and issued a proposed adverse ruling as to
petitioner’s private foundation classification. By letter dated
July 14, 2000, respondent supplied additional grounds for the
proposed adverse ruling. The final submission from petitioner
contained in the administrative record is a letter with
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011