Roger and Sharon Wortmann, et al. - Page 8

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          remaining personal property inside the buildings that had not               
          been sold at auction.  TRY granted the Monks Nonprofit a right of           
          first refusal on the subject property, as Father Stevens wished,            
          which gave the Monks Nonprofit the right to repurchase the                  
          property if TRY were ever to offer the subject property for sale.           
               After TRY acquired the subject property, petitioners located           
          a separate, rural group of deacons to operate the subject                   
          property.  This group of deacons incorporated their operation               
          under the name Tinter Retreat & Resource Center, Inc. (TRRC).               
          TRRC applied for and received a determination from respondent               
          that it operated as a section 501(c)(3) organization.  TRY leased           
          the subject property to TRRC for $1, and TRRC operated it for               
          approximately 17 months.  During this time, TRRC painted the                
          buildings, replaced carpeting, maintained the outside of the                
          structures, created separate sleeping areas for men and women,              
          completed the bathrooms, and added various sports fields.  These            
          improvements were essentially for general maintenance and upkeep.           
          Neither TRY nor petitioners individually expended any time or               
          money to make any structural improvements or additions to the               
          subject property.                                                           
               On October 29, 1998, TRY donated the subject property to               
          TRRC.  TRY claimed a charitable contribution of $475,000 for the            
          subject property.5  In connection with donating the subject                 
          property to TRRC, Mr. Archbold suggested to a TRRC board member             

               5TRC also claimed a charitable contribution of $76,082 for             
          the personal property inside the subject property buildings,                
          which is not at issue here.                                                 




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