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Guzman (902 E. Crockett); $1,000 to Sara Guzman; $500
to Jean Parker; $3,300 to J. Guy Sowells (517 Center);
and $3,300 to James Goodman (525 Center Street). No
lease agreements were produced by the school, and no
real estate transactions supporting these transactions
were found during a deed records search.
16. Ms. Fennell bought the property at 902 E.
Crockett from Alfred Guzman as an individual and not as
a representative of RSSAT. Ms. Fennell issued Rameses
School check Number 0454, dated October 9, 1998, to
Mr. Guzman as a payment for the property. [Citations
omitted.]
The foregoing factual circumstances, independently borne out
by the documentary record, are more than sufficient to establish
prohibited private benefit. Furthermore, even if petitioner were
permitted to challenge the SBOE findings, its response on brief
consists solely of short, unsupported, and conclusory statements
of denial. For example, the school’s entire argument on opening
brief on the inurement and private benefit issue reads:
Plaintiff presented witnesses to testify that board
meetings were regularly conducted and that Plaintiff
did not personally benefit or receive personal gains.
Plaintiff explains reimbursement of single RAMESES
check at a dentist office. Plaintiff was without
available checks at the time and duly reimbursed
RAMESES SCHOOL.
Similar blanket statements on reply brief are equally
unpersuasive in the face of the detailed evidence.
Hence, the Court is constrained to hold on the entire record
in this case that, on account of proscribed private benefit,
petitioner was not operated exclusively for exempt purposes
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