South Community Association - Page 3

                                        - 3 -                                         
          conduct any gaming activity.  According to its bylaws,                      
          petitioner’s exempt purpose was (and is) to provide aid for all             
          forms of education.  At some time between August 3, 1982, and               
          January 1, 1992, petitioner began a gaming operation (gaming                
          operation).  The gaming operation was the idea of Parr, who                 
          during the relevant years did not work for petitioner but whose             
          company sold to petitioner the supplies that petitioner used in             
          the gaming operation.                                                       
               From 1992 until 1995, the years audited by respondent in               
          connection with his determination revoking petitioner’s                     
          exemption, petitioner contributed $1,423,729 to various charities           
          generally for the purposes of starting educational programs,                
          building a school, and transporting handicapped individuals to              
          various schools.  Petitioner’s contributions during the                     
          respective years were $440,055, $323,088, $386,599, and $273,987.           
          Many of the recipients of these contributions were charities                
          controlled by petitioner’s president, James Clausing (Clausing).            
          Petitioner funded its contributions almost entirely through its             
          gaming operation.                                                           
               Petitioner’s gaming operation consisted of its sale of bingo           
          cards and instant pull-tab tickets.3  Petitioner sold its bingo             

               3 Each of petitioner’s instant pull-tab tickets was a paper            
          ticket with a covered symbol.  Upon purchasing an instant                   
          pull-tab ticket and uncovering the symbol, the purchaser won a              
          prize if the symbol was one that was predesignated to win.                  

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