- 9 - Subsequently, on March 3, 2000, the SBOE issued a final order denying the school’s motion for rehearing. IRS Examination Examination by the IRS into petitioner’s tax-exempt status began in late 2001, precipitated by the forwarding to the IRS of a newspaper article reporting the revocation of the school’s charter. The IRS conducted an investigation into whether petitioner complied with the standards imposed under section 501(c)(3). In particular, the IRS sought financial and governance records in order to verify the information reported by petitioner on Forms 990, Return of Organization Exempt from Income Tax, and to evaluate the records for possible instances of private benefit and personal inurement. To that end, dozens of information document requests were issued to petitioner, but only a very limited portion of the requested materials was ever provided, and often only after repeated inquiries, missed or delayed appointments, and a general lack of cooperation on the part of petitioner. Consequently, additional information was sought and obtained from third-party sources, including public records and the TEA. The examination culminated with issuance on September 8, 2004, of the final adverse determination underlying this litigation. The conclusion was that petitioner failed to establish that it was operated exclusively for an exempt purpose,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007