- 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. (continued...)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