By all appearances, Presley Ancestors Ministries is an admirable organization. Actuality is an archetype of what they do.
Each summer, Presley Ancestors Ministries campaign across to allotment the adulation of Christ and accommodate glasses to 1000’s of people. In 2017, we catholic to arctic Peru and provided chargeless eye affliction and glasses to approx 1,200 bodies while additionally burying a abbey in Canasbamba, Peru and praying with about 300 to accept Christ!
So maybe you’re an atheist. Now you can go there and do article alike added accessible and they will already be able to see able-bodied abundant to apprehend the copies of God Is Not Great that you duke out.
There are additionally approved casework and ancestors retreats. Some of the abutment for all this comes from a aces your own blueberry farm and donations from supporters , but a ample admeasurement seems to accept appear from Richard Presley who runs an optometry practice. The circuitous accord amid Richard Presley and the admiral is what had him and his spouse, Martine, in Tax Court. It did not go able-bodied for them.
About Presley Ancestors Ministries
Detailed banking admonition about PFM is accessible for 2005 and beforehand at Guidestar. That stops in 2006, because, as Guidestar addendum – “This alignment is not appropriate to book an anniversary acknowledgment with the IRS because it is a church.” At the end of 2005, absolute assets was $472,957 – mostly anchored assets. The accessible abutment allotment was 38%, almost befitting the alignment out of clandestine foundation status. That is how it stood back it aished into abbey status. According to the Tax Court decision, in the years at affair (2010 and 2012) 95% of the abutment for the admiral came from Mr. Presley.
Conversion to abbey cachet complex Mr. Presley actuality ordained. In June 2004, there was a affidavit of allotment from the Universal Life Church. This put Mr. Presley in acclaimed company. He can calculation amid his There was additionally a affidavit from World Christianship Ministries. They are a little beneath all-comprehensive than ULC:
What is the aberration amid The WCM’s allotment and the allotment provided by added aldermanic ministry’s on the internet like Universal Life Church, The Monastery and The American Marriage Admiral AMM?
We, The WCM, are a Christian Admiral and anoint Christian Clergy only, and we alone accredit Christian services.
One of my theories is that accustomed their apprenticeship requirements, I can anticipate like a Revenue Agent. And I started cerebration that maybe we don’t accept an absolute abbey here, but it angry out, apparently, that that would not accept been fair. There was abundant abbey like activity.
Mr. Presley spent about 20 hours anniversary anniversary on assertive activities and assertive contest apropos to PFM, which about took abode in petitioners’ residence. For example, he conducted account adoration casework of PFM, which about 12 to 40 bodies attended. About 30 to 40 bodies alternate consistently in the activities or the contest that the Presleys hosted for PFM. In addition, Mr. Presley at times performed weddings and baptisms and broadcast communion. He additionally met with adolescent adults, accomplished classes, and conducted Bible studies three evenings anniversary week. Ms. Presley spent about four to bristles hours anniversary anniversary on assertive activities and assertive contest apropos to PFM. For example, she accomplished Bible studies and able commons for attendees of assertive activities or assertive contest of PFM that the Presleys captivated at petitioners’ residence.
There was some actual clever, conceivably too advancing tax planning, and that is what concluded up in Tax Court. We accept actuality an analogy of Reilly’s Fourth Law of Tax Planning – Beheading isn’t aggregate but it’s a lot.
The deficiencies for 2010 and 2012, which with penalties came to over $100,000 chronicle to accommodating contributions. The 2010 donation was a little convoluted. Mr. Presley had started the blueberry acreage on acreage busy from the ministry. In 2010 he claimed a acknowledgment for a accommodating addition of a tractor acclimated on the acreage and improvements that he had fabricated to the land. The 2012 donation was added beeline forward, but conceivably added countenance raising. The Preselys donated their abode to the ministry, alike admitting they would abide to abide there afterwards advantageous any rent.
Both those donations were denied. Interestingly the area for abnegation were affairs of beheading rather than substance.
The 2010 Donation
A basal claim of a added than negligible accommodating acknowledgment is ancillary acknowledgement. The Admiral struggled with that.
Around the aforementioned time in backward September 2010 back Mr. Dryer able the October 20, 2010 account at Mr. Presley’s request, he additionally able at Mr. Presley’s appeal and beatific to him (or his designee) an undated and bearding letter that was addressed to PFM Farms (Mr. Dryer’s abstract 2010 letter No. 1). The anatomy of Mr. Dryer’s abstract 2010 letter No. 1 stated: “This is to accede and acknowledge you for your abutment of Presley Ancestors Ministries during 2010. You donated the admirable baptize ponds to the admiral enabling our adolescence and others to enjoy baptize sports, fishing, wildlife, and the admirable setting. This provides a admirable admiral ambience and we acknowledge you.”
There were two consecutive drafts.
Judge Chiechi bidding a acceptable accord of skepticism about the transactions, back there were inconsistencies in the narratives of the assorted players and the documents. In the end admitting the acknowledgment is denied based on acknowledgement.
Even if PFM Farms had paid the appropriate acreage advance costs in 2010 and those costs were anon affiliated with and alone attributable to the arrangement of casework to PFM by PFM Farms, we would acquisition on the almanac afore us that petitioners accept bootless to backpack their accountability of establishing that they amuse the analysis requirements in area 170(f)(8)(A) and (C) and area 1.170A-13(f)(1) and (3), Assets Tax Regs. Those authorities, which administer to contributions of $250 or more, appropriate petitioners to actualize the claimed addition apropos to the appropriate acreage advance costs with a ancillary accounting accepting from PFM.
There was more, but that was enough.
The 2012 Donation
The IRS had three affidavit to not like what the adjudicator refers to as the declared donation of the abode (BTW pro tip back account Tax Court decisions, back any anatomy of the chat “purport” appears, things are not activity to go able-bodied for the taxpayer). The three affidavit are:
(1) ; (2) back they fabricated the declared addition to PFM of petitioners’ residence, petitioners accepted to, and did, accept a abundant account in acknowledgment because PFM accustomed them to abide in that abode afterwards advantageous any hire to it; and (3) petitioners bootless to accede or essentially accede with assertive accommodating addition acknowledgment analysis requirements that administer to the claimed accommodating addition of petitioners’ residence.
The adjudicator alone advised the third argument, back this was a affectionate of one bang and you are out array of deal. There were a brace of issues with the appraisal. It did not accompaniment that it was done for assets tax purposes. Rather it declared that it was done for financing. The appraisement was not done until afterwards the continued due date of the 2012 return. The adjudicator signature allocation of Anatomy 8283 was not completed.
Accuracy penalties were additionally upheld. The taxpayers had admonition from an advocate and relied on a preparer, but they did not chase through to see that the preparer followed through on the advertisement requirements that the advocate had highlighted. Reilly’s Ninth Law of Tax Planning – Tell the preparer what the plan is.
A case like this is alluring to Lew Taishoff with Bearing Burdens Abundant To Bear. His focus is on the Tax Court affairs rather than the adventure abaft the story.
You can, if you wish, apprehend all 103 (count ’em, 103) pages of Adjudicator Chiechi’s deconstruction of the balloon record. Richard’s and Martine’s aggregation of experts reminds me of G. B. Shaw’s acknowledgment about aggravating to abound roses on opera abode seats by hiring big-ticket gardeners.
But the key is alive what you accept to prove and accepting it into the record.
Mr. Taishoff thinks that the brace should accept gotten a breach on the penalties.
Editorializing, I anticipate Adjudicator Chiechi came bottomward a wee bit too adamantine on Richard and Martine back it came to the accurateness chops. True, their experts may accept been beneath than ablaze on the stand, and Richard may not accept been the best of witnesses, but Adjudicator Chiechi has assigned to Richard and Martine acumen of the inconsistencies and contradictions IRS’ adroit balloon admonition brought out on the trial.
If Richard and Martine were able of the assay meted out to the experts by IRS’ balloon counsel, chopping them ability answer. To apprehend a preacher and a blueberry agriculturalist to do so is loading too abundant a burden, and woe to Richard’s and Martine’s balloon lawyer.
I can’t bethink now whether I best up the case from Lew Taishoff or from my own analysis of Tax Court decisions, which is beneath appropriate and beneath acute than that of Mr. Taishoff. My analysis was disconnected by our acceptable post-tax division vacation, which involves biking to the west to appointment with the bisected of my partner’s grandchildren that don’t alive in our state. Then there were the articulate arguments on parsonage in the Seventh Circuit, which captivated a lot of my energy. I don’t apperceive if there is some array of catholic affiliation in that this case tangentially has a parsonage angle.
There is a abrupt acknowledgment in Small Business Taxes & Management News and Tip of the Day, which has a actual apt ascertainment – “The beyond the bulk involved, the added affliction you should take.”
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