- 15 - (1980), affd. without published opinion 647 F.2d 163 (2d Cir. 1981). Factors emerging repeatedly as indicative of prohibited inurement and private benefit include control by the founder over the entity’s funds, assets, and disbursements; use of entity moneys for personal expenses; payment of salary or rent to the founder without any accompanying evidence or analysis of the reasonableness of the amounts; and purported loans to the founder showing a ready private source of credit. See, e.g., Founding Church of Scientology v. United States, supra at 1200-1202; Church of Eternal Life & Liberty, Inc. v. Commissioner, supra at 927-928; Church of the Transfiguring Spirit, Inc. v. Commissioner, supra at 5-6; Basic Bible Church v. Commissioner, supra at 857-858; Bubbling Well Church of Universal Love, Inc. v. Commissioner, supra at 534-538; Unitary Mission Church v. Commissioner, supra at 513-515. As this Court has noted, such circumstances provide “an obvious opportunity for abuse of the claimed tax-exempt status” and make incumbent “open and candid disclosure of all facts”; otherwise, “the logical inference is that the facts, if disclosed, would show that petitioner fails to meet the requirements of section 501(c)(3).” Bubbling Well Church of Universal Love, Inc. v. Commissioner, supra at 535; see also, e.g., Founding Church of Scientology v. United States, supra at 1201; Basic Bible Church v. Commissioner, supra at 858.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007