Rameses School of San Antonio, Texas - Page 15




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          (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.            







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