United in Purpose

“It appears the Bylaws permit the Taxpayer's incorporator to appoint members to the Board of Directors to fill vacancies. The Taxpayer is in the process of approving new governing documents to change this process and create a self-perpetuating Board of Directors.”

“It does not appear the Board of Directors met in 2019, and therefore no meeting minutes have been identified. Written consent actions for 2019 also have not been identified.”

“It appears that committees did not keep meeting minutes.”

“The draft tax return was reviewed by those individuals charged with handling financial matters. The final return was provided to the entire board prior to filing the tax return.”

“While an annual statement was required, such statements were not provided, and instead, directors, officers, and members of committees with board-delegated powers were required by Taxpayer's Conflict of Interest Policy to contemporaneously disclose conflicts of interest as they arose. Taxpayer's practice appears to have been also to adopt/renew its Conflict of Interest Policy annually.”

“Taxpayer's Bylaws required compensation for directors and officers to be approved by a majority of its Board of Directors. A new Executive Compensation Policy has been adopted to require an independent compensation committee, review of comparability data, and contemporaneous substantiation of the committee's deliberation and decisions in the future. Further, a board meeting was not held in 2019 to approve a budget or executive compensation.”

“The Organization makes its governing documents and policies, exemption application, and tax returns available to the general public upon request.”

“William Dallas - 300 11th St, Montara, CA 94037. Reid Rutherford - 10737 Magdalena Road, Los Altos Hills, CA 94024. Robert D McEwen - 10935 Rice Field Place, Suite 101, Fairfax Station, VA 22039. David Barton - PO Box 397, Aledo, TX 76008-0397.”

“The Organization acts as a common paying agent to pay shared employees, file payroll tax returns and issue Form W-2s. The forms were issued under this organization's federal identification number. The amounts reported in Parts VII and IX are only for the unreimbursed compensation and benefits paid on behalf of this organization.”