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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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