Rameses School of San Antonio, Texas - Page 9




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          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,           







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