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Drive. In June 2004 CSE acquired property at 100 Cummings Road. In August 2005 CSE acquired property at 120 Oleander Drive. The Creation Science Evangelism Foundation held title to the properties.
CSE built a biblically themed amusement park, DAL, on the acquired properties.[1] DAL featured rides, a museum, and a science center. DAL provided tours for visitors and hosted birthday parties. DAL charged admission for entry to the park, sold concessions, and offered merchandise for sale.
VI. Operation of CSE
During the years at issue Mr. Hovind and petitioner operated CSE as an unincorporated entity.[2] CSE maintained its primary office at 29 Cummings Drive.
From January 1, 1998, through August 31, 2006, CSE maintained an account ending in 8656 (account 8656) at AmSouth Bank. From October 17,
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- ↑ There was no division between the operations or finances of CSE and DAL. Employees often performed tasks for both CSE and DAL. DAL was not organized as a separate entity. Accordingly, we find that DAL was an asset of CSE and its revenue and expenses were properly treated as revenue and expenses of CSE.
- ↑ Special Agent Scott Schneider discovered no corporate or partnership documents during the course of his investigation.
