[QUOTE=luvmytbs;6967162]
Um, they didn’t spend 775,000 on horse care. They didn’t own or house the horses they sold, Brian Moore did.[/QUOTE]
They have, by some estimates, about 40 in their Rescue [ie the rare bred horses or those of such lineage that they want to keep them for themselves, so they say they are for adoption but never in fact get adopted.]… then again their Kiger/whatever stallion that SOME VET said [per blood tests] was not a stallion also has some foals on the ground w/ at least 2 mares and several other mares are ‘no longer available’ and one does wonder…, so the number may be swelling, so to speak
But again, 775k on 40 horses when you see how those horses have not blossomed in their care therefore are not getting top notch … anything… is not imaginable.
But I agree with you, the majority of the $$ in, and then out again of the rescue coffers was for Broker owned horses which has clearly been the majority of their ‘work’ for years… ie went to B Moore.
RE Inurement, very interesting to read, really:
http://webcache.googleusercontent.com/search?q=cache:iQWLH5Laa6gJ:http://www.irs.gov/pub/irs-tege/eotopicc90.pdf%2Binurement+nonprofit&hl=en&gbv=2&gs_l=heirloom-hp.1.2.0l9j0i10.15744.17802.1.20084.7.7.0.0.0.0.65.416.7.7.0...0.0...1ac.1.jiAS4LGrD_8&ct=clnk
[i]IntroductionIRC 501©(3) provides exemption from federal income tax for organizationsthat are “organized and operated exclusively” for religious, educational, orcharitable purposes. The exemption is further conditioned on the organizationbeing one “no part of the net income of which inures to the benefit of any privateshareholder or individual.” This article examines the proscription againstinurement and the requirement that an organization must be organized andoperated exclusively for exempt purposes by serving public rather than private interests…
Regs. 1.501(a)-1© states that “[t]he words ‘private shareholder orindividual’ in section 501 refer to persons having a personal and private interest inthe activities of the organization.”…
However, any transaction between an organization and a private individual inwhich the individual appears to receive a disproportionate share of the benefits ofthe exchange relative to the charity served presents an inurement issue. Suchtransactions may include assignments of income, compensation arrangements,sales or exchanges of property, commissions, rental arrangements, gifts withretained interests, and contracts to provide goods or services to the organization…
The general rule is that if the arrangements are indistinguishable from ordinaryprudent business practices in comparable circumstances, a fair exchange ofbenefits is presumed and inurement will not be found. If the transactions departfrom that standard to the benefit of an individual, a finding of inurement should be made.[/i]
Cause everyone hands over at least $25k to a horse dealer each month, right?
[i]Other case examples of inurement include payment of excessive rent, TexasTrade School v. Commissioner, 30 T.C. 642, aff’d. 272 F.2d 168 (5th Cir. 1959);…
A common factual thread running through the cases where inurement hasbeen found is that the individual stands in a relationship with the organizationwhich offers him the opportunity to make use of the organization’s income orassets for personal gain…[/i]
There’s alot more but I was up early, out all day and will be again tomorrow… so you’re on your own.
