TIN:
SCHEDULE A
(Form 990 or 990EZ)
Department of the Treasury
Internal Revenue Service
(Form 990 or 990EZ)
Department of the Treasury
Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. Go to
www.irs.gov/Form990 for instructions and the latest information.
OMB No. 1545-0047
2020
Open to Public
Inspection
Inspection
Name of the organization
THE GREATER RENO COMMUNITY
ICE SKATING ASSOCIATION
ICE SKATING ASSOCIATION
Employer identification number
46-5526756
46-5526756
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions.
The organization is not a private foundation because it is: (For lines 1 through 12, check only one box.)
1
2
3
4
5
6
7
8
9
10
11
12
a
b
c
d
e
f
Enter the number of supported organizations
...............................
g
Provide the following information about the supported organization(s).
| (i) Name of supported organization | (ii) EIN | (iii) Type of organization (described on lines 1- 10 above (see instructions)) | (iv) Is the organization listed in your governing document? | (v) Amount of monetary support (see instructions) | (vi) Amount of other support (see instructions) | |
|---|---|---|---|---|---|---|
| Yes | No | |||||
|
Total |
||||||
For Paperwork Reduction Act Notice, see the Instructions for
Form 990 or 990-EZ.
Form 990 or 990-EZ.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 2
Part II
Support Schedule for Organizations Described in Sections 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)
(Complete only if you checked the box on line 5, 7, or 8 of Part I or if the organization failed to qualify under Part III. If the organization failed to qualify under the tests listed below, please complete Part III.)
(Complete only if you checked the box on line 5, 7, or 8 of Part I or if the organization failed to qualify under Part III. If the organization failed to qualify under the tests listed below, please complete Part III.)
| Calendar year (or fiscal year beginning in) |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") .. | 5,000 | 200,000 | 172,026 | 428,960 | 4,448,665 | 5,254,651 |
| 2 | Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.... | ||||||
| 3 | The value of services or facilities furnished by a governmental unit to the organization without charge.. | ||||||
| 4 | Total. Add lines 1 through 3 | 5,000 | 200,000 | 172,026 | 428,960 | 4,448,665 | 5,254,651 |
| 5 | The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included on line 1 that exceeds 2% of the amount shown on line 11, column (f).. | 4,371,073 | |||||
| 6 | Public support. Subtract line 5 from line 4. | 883,578 | |||||
| Calendar year
(or fiscal year beginning in) |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 7 | Amounts from line 4.. | 5,000 | 200,000 | 172,026 | 428,960 | 4,448,665 | 5,254,651 |
| 8 | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources... | 2 | 40 | 19,780 | 19,822 | ||
| 9 | Net income from unrelated business activities, whether or not the business is regularly carried on.. | ||||||
| 10 | Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.).. | ||||||
| 11 | Total support. Add lines 7 through 10 | 5,274,473 | |||||
12
12
83,465
13
First 5 years.
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a section 501(c)(3) organization,
check this box and stop here........................................
Section C. Computation of Public Support Percentage
14
14
16.750 %
15
15
31.560 %
16a
b
17a
b
18
Private foundation.
If the organization did not check a box on line 13, 16a, 16b, 17a, or 17b, check this box and see
instructions .....................................................
instructions .....................................................
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 3
Part III
Support Schedule for Organizations Described in Section 509(a)(2)
(Complete only if you checked the box on line 10 of Part I or if the organization failed to qualify under Part II. If the organization fails to qualify under the tests listed below, please complete Part II.)
(Complete only if you checked the box on line 10 of Part I or if the organization failed to qualify under Part II. If the organization fails to qualify under the tests listed below, please complete Part II.)
| Calendar year (or fiscal year beginning in) |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") . | ||||||
| 2 | Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose | ||||||
| 3 | Gross receipts from activities that are not an unrelated trade or business under section 513 ..... | ||||||
| 4 | Tax revenues levied for the organization's benefit and either paid to or expended on its behalf... | ||||||
| 5 | The value of services or facilities furnished by a governmental unit to the organization without charge | ||||||
| 6 | Total. Add lines 1 through 5 | ||||||
| 7a | Amounts included on lines 1, 2, and 3 received from disqualified persons | ||||||
| b | Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year. | ||||||
| c | Add lines 7a and 7b.. | ||||||
| 8 | Public support. (Subtract line 7c from line 6.) | ||||||
| Calendar year (or fiscal year beginning in) |
(a) 2016 | (b) 2017 | (c) 2018 | (d) 2019 | (e) 2020 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 9 | Amounts from line 6... | ||||||
| 10a | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources.. | ||||||
| b | Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975. | ||||||
| c | Add lines 10a and 10b. | ||||||
| 11 | Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on. | ||||||
| 12 | Other income. Do not include gain or loss from the sale of capital assets (Explain in Part VI.) .. | ||||||
| 13 | Total support. (Add lines 9, 10c, 11, and 12.).. | ||||||
14
Section C. Computation of Public Support Percentage
15
15
16
16
Section D. Computation of Investment Income Percentage
17
17
18
18
19a
b
20
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 4
Part IV
Supporting Organizations
(Complete only if you checked a box on line 12 of Part I. If you checked box 12a, of Part I, complete
Sections A and B. If you checked box 12b, of Part I, complete Sections A and C. If you checked box 12c, of
Part I, complete Sections A, D, and E. If you checked box12d, of Part I, complete Sections A and D, and
complete Part V.)
Section A. All Supporting Organizations
Yes
No
1
Are all of the organization’s supported organizations listed by name in the organization’s governing documents?
If "No," describe in Part VI how the supported organizations are designated. If designated by class or purpose,
describe the designation. If historic and continuing relationship, explain.
If "No," describe in Part VI how the supported organizations are designated. If designated by class or purpose,
describe the designation. If historic and continuing relationship, explain.
1
2
Did the organization have any supported organization that does not have an IRS determination of status under section 509(a)(1) or (2)? If "Yes," explain in Part VI how the organization determined that the supported organization was
described in section 509(a)(1) or (2).
2
3a
Did the organization have a supported organization described in section 501(c)(4), (5), or (6)?
If "Yes," answer lines 3b and 3c below.
3a
b
Did the organization confirm that each supported organization qualified under section 501(c)(4), (5), or (6) and satisfied the
public support tests under section 509(a)(2)? If "Yes," describe in Part VI when and how the organization made the
determination.
3b
c
Did the organization ensure that all support to such organizations was used exclusively for section 170(c)(2)(B) purposes?
If "Yes," explain in Part VI what controls the organization put in place to ensure such use.
3c
4a
Was any supported organization not organized in the United States ("foreign supported organization")?
If “Yes” and if you checked box 12a or 12b in Part I, answer lines 4b and 4c below.
4a
b
Did the organization have ultimate control and discretion in deciding whether to make grants to the foreign supported
organization? If “Yes,” describe in Part VI how the organization had such control and discretion despite being controlled or
supervised by or in connection with its supported organizations.
4b
c
Did the organization support any foreign supported organization that does not have an IRS determination under sections
501(c)(3) and 509(a)(1) or (2)?
If “Yes,” explain in Part VI what controls the organization used to ensure that all support to
the foreign supported organization was used exclusively for section 170(c)(2)(B) purposes.
4c
5a
Did the organization add, substitute, or remove any supported organizations during the tax year?
If “Yes,” answer lines 5b and 5c below (if applicable). Also, provide detail in Part VI, including (i) the names and EIN numbers
of the supported organizations added, substituted, or removed; (ii) the reasons for each such action; (iii) the authority under the
organization's organizing document authorizing such action; and (iv) how the action was accomplished (such as by
amendment to the organizing document).
5a
b
Type I or Type II only. Was any added or substituted supported organization part of a class already designated in the
organization's organizing document?
5b
c
Substitutions only. Was the substitution the result of an event beyond the organization's control?
5c
6
Did the organization provide support (whether in the form of grants or the provision of services or facilities) to anyone other
than (i) its supported organizations, (ii) individuals that are part of the charitable class benefited by one or more of its
supported organizations, or (iii) other supporting organizations that also support or benefit one or more of the filing
organization’s supported organizations?
If “Yes,” provide detail in Part VI.
6
7
Did the organization provide a grant, loan, compensation, or other similar payment to a substantial contributor (defined in
section 4958(c)(3)(C)), a family member of a substantial contributor, or a 35% controlled entity with regard to a
substantial contributor?
If “Yes,” complete Part I of Schedule L (Form 990 or 990-EZ) .
7
8
Did the organization make a loan to a disqualified person (as defined in section 4958) not described in line 7?
If “Yes,” complete Part I of Schedule L (Form 990 or 990-EZ).
8
9a
Was the organization controlled directly or indirectly at any time during the tax year by one or more disqualified persons, as
defined in section 4946 (other than foundation managers and organizations described in section 509(a)(1) or (2))?
If “Yes,” provide detail in Part VI.
9a
b
Did one or more disqualified persons (as defined in line 9a) hold a controlling interest in any entity in which the supporting
organization had an interest?
If “Yes,” provide detail in Part VI.
9b
c
Did a disqualified person (as defined in line 9a) have an ownership interest in, or derive any personal benefit from, assets
in which the supporting organization also had an interest?
If “Yes,” provide detail in Part VI.
9c
10a
Was the organization subject to the excess business holdings rules of section 4943 because of section 4943(f) (regarding certain
Type II supporting organizations, and all Type III non-functionally integrated supporting organizations)?
If “Yes,” answer line 10b below.
10a
b
Did the organization have any excess business holdings in the tax year? (Use Schedule C, Form 4720, to determine
whether the organization had excess business holdings).
10b
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 5
Part IV
Supporting Organizations (continued)
Yes
No
11
Has the organization accepted a gift or contribution from any of the following persons?
a
A person who directly or indirectly controls, either alone or together with persons described in lines 11b and 11c below,
the governing body of a supported organization?
11a
b
A family member of a person described in 11a above?
11b
c
A 35% controlled entity of a person described in line 11a or 11b above?
If “Yes” to 11a, 11b, or 11c, provide detail in Part VI.
11c
Section B. Type I Supporting Organizations
Yes
No
1
Did the officers, directors, trustees, or membership of one or more supported organizations have the power to regularly appoint or
elect at least a majority of the organization’s directors or trustees at all times during the tax year?
If “No,” describe in Part VI how the supported organization(s) effectively operated, supervised, or controlled the
organization’s activities. If the organization had more than one supported organization, describe how the powers to appoint
and/or remove directors or trustees were allocated among the supported organizations and what conditions or restrictions, if any,
applied to such powers during the tax year.
1
2
Did the organization operate for the benefit of any supported organization other than the supported organization(s) that
operated, supervised, or controlled the supporting organization?
If “Yes,” explain in Part VI how providing such benefit
carried out the purposes of the supported organization(s) that operated, supervised or controlled the supporting
organization.
2
Section C. Type II Supporting Organizations
Yes
No
1
Were a majority of the organization’s directors or trustees during the tax year also a majority of the directors or trustees of
each of the organization’s supported organization(s)?
If “No,” describe in Part VI how control or management of the
supporting organization was vested in the same persons that controlled or managed the supported organization(s).
1
Section D. All Type III Supporting Organizations
Yes
No
1
Did the organization provide to each of its supported organizations, by the last day of the fifth month of the organization’s
tax year, (i) a written notice describing the type and amount of support provided during the prior tax year, (ii) a copy of the
Form 990 that was most recently filed as of the date of notification, and (iii) copies of the organization’s governing
documents in effect on the date of notification, to the extent not previously provided?
1
2
Were any of the organization’s officers, directors, or trustees either (i) appointed or elected by the supported organization(s)
or (ii) serving on the governing body of a supported organization?
If "No," explain in Part VI how the organization
maintained a close and continuous working relationship with the supported organization(s).
2
3
By reason of the relationship described in line 2 above, did the organization’s supported organizations have a significant voice in the
organization’s investment policies and in directing the use of the organization’s income or assets at all times during the tax year?
If "Yes," describe in Part VI the role the organization’s supported organizations played in this regard.
3
Section E. Type III Functionally-Integrated Supporting Organizations
1
Check the box next to the method that the organization used to satisfy the Integral Part Test during the year
(see instructions):
a
b
c
2
Activities Test. Answer lines 2a and 2b below.
Yes
No
a
Did substantially all of the organization’s activities during the tax year directly further the exempt purposes of the supported
organization(s) to which the organization was responsive?
If "Yes," then in Part VI identify those supported
organizations and explain how these activities directly furthered their exempt purposes, how the organization was
responsive to those supported organizations, and how the organization determined that these activities constituted
substantially all of its activities.
2a
b
Did the activities described in line 2a, above constitute activities that, but for the organization’s involvement, one
or more of the organization’s supported organization(s) would have been engaged in?
If "Yes," explain in Part VI the reasons for the
organization’s position that its supported organization(s) would have engaged in these activities but for the organization’s
involvement.
2b
3
Parent of Supported Organizations. Answer lines 3a and 3b below.
a
Did the organization have the power to regularly appoint or elect a majority of the officers, directors, or trustees of each of
the supported organizations?If "Yes" or "No", provide details in Part VI.
3a
b
Did the organization exercise a substantial degree of direction over the policies, programs and activities of each of its
supported organizations?
If "Yes," describe in Part VI. the role played by the organization in this regard.
3b
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 6
Part V
Type III Non-Functionally Integrated 509(a)(3) Supporting Organizations
1
| Section A - Adjusted Net Income | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Net short-term capital gain | 1 | ||||
| 2 | Recoveries of prior-year distributions | 2 | ||||
| 3 | Other gross income (see instructions) | 3 | ||||
| 4 | Add lines 1 through 3 | 4 | ||||
| 5 | Depreciation and depletion | 5 | ||||
| 6 | Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions) | 6 | ||||
| 7 | Other expenses (see instructions) | 7 | ||||
| 8 | Adjusted Net Income (subtract lines 5, 6 and 7 from line 4) | 8 | ||||
| Section B - Minimum Asset Amount | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year): | 1 | ||||
| a | Average monthly value of securities | 1a | ||||
| b | Average monthly cash balances | 1b | ||||
| c | Fair market value of other non-exempt-use assets | 1c | ||||
| d | Total (add lines 1a, 1b, and 1c) | 1d | ||||
| e |
Discount claimed for blockage or other factors (explain in detail in Part VI): |
|||||
| 2 | Acquisition indebtedness applicable to non-exempt use assets | 2 | ||||
| 3 | Subtract line 2 from line 1d | 3 | ||||
| 4 | Cash deemed held for exempt use. Enter 0.015 of line 3 (for greater amount, see instructions). | 4 | ||||
| 5 | Net value of non-exempt-use assets (subtract line 4 from line 3) | 5 | ||||
| 6 | Multiply line 5 by 0.035 | 6 | ||||
| 7 | Recoveries of prior-year distributions | 7 | ||||
| 8 | Minimum Asset Amount (add line 7 to line 6) | 8 | ||||
| Section C - Distributable Amount | Current Year | |||||
| 1 | Adjusted net income for prior year (from Section A, line 8, Column A) | 1 | ||||
| 2 | Enter 85% of line 1 | 2 | ||||
| 3 | Minimum asset amount for prior year (from Section B, line 8, Column A) | 3 | ||||
| 4 | Enter greater of line 2 or line 3 | 4 | ||||
| 5 | Income tax imposed in prior year | 5 | ||||
| 6 | Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions) | 6 | ||||
7
Schedule A (Form 990 or 990-EZ) 2020
Schedule A (Form 990 or 990-EZ) 2020
Page 7
| Section D - Distributions | Current Year | |
|---|---|---|
| 1 Amounts paid to supported organizations to accomplish exempt purposes | 1 | |
|
2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
2 | |
| 3 Administrative expenses paid to accomplish exempt purposes of supported organizations | 3 | |
| 4 Amounts paid to acquire exempt-use assets | 4 | |
| 5 Qualified set-aside amounts (prior IRS approval required - provide details in Part VI) | 5 | |
| 6 Other distributions (describe in Part VI). See instructions | 6 | |
| 7Total annual distributions. Add lines 1 through 6. | 7 | |
|
8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
8 | |
| 9 Distributable amount for 2020 from Section C, line 6 | 9 | |
| 10 Line 8 amount divided by Line 9 amount | 10 | |
| Section E - Distribution Allocations (see instructions) |
(i) Excess Distributions |
(ii) Underdistributions Pre-2020 |
(iii) Distributable Amount for 2020 |
|
|---|---|---|---|---|
| 1 Distributable amount for 2020 from Section C, line 6 | ||||
|
2
Underdistributions, if any, for years prior to 2019 (reasonable cause required-- explain in Part VI). See instructions. |
||||
| 3 Excess distributions carryover, if any, to 2020: | ||||
| a From 2015....... | ||||
| b From 2016....... | ||||
| c From 2017....... | ||||
| d From 2018....... | ||||
| e From 2019....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2020 distributable amount | ||||
|
i
Carryover from 2015 not applied (see instructions) |
||||
| j Remainder. Subtract lines 3g, 3h, and 3i from line 3f. | ||||
| 4Distributions for 2020 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2020 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from line 4. | ||||
|
5
Remaining underdistributions for years prior to 2020, if any. Subtract lines 3g and 4a from line 2. If the amount is greater than zero, explain in Part VI. See instructions. |
||||
|
6
Remaining underdistributions for 2020. Subtract lines 3h and 4b from line 1. If the amount is greater than zero, explain in Part VI. See instructions. |
||||
|
7 Excess distributions carryover to 2021. Add lines 3j and 4c. |
||||
| 8 Breakdown of line 7: | ||||
| a Excess from 2016..... | ||||
| b Excess from 2017..... | ||||
| c Excess from 2018..... | ||||
| d Excess from 2019..... | ||||
| e Excess from 2020..... | ||||
Schedule A (Form 990 or 990-EZ) (2020)
Schedule A (Form 990 or 990-EZ) 2020
Page 8
Part VI
Supplemental Information.
Provide the explanations required by Part II, line 10; Part II, line 17a or 17b; Part III, line 12; Part IV, Section A, lines 1, 2, 3b, 3c, 4b, 4c, 5a, 6, 9a, 9b, 9c, 11a, 11b, and 11c; Part IV, Section B, lines 1 and 2; Part IV, Section C, line 1; Part IV, Section D, lines 2 and 3; Part IV, Section E, lines 1c, 2a, 2b, 3a and 3b; Part V, line 1; Part V, Section B, line 1e; Part V Section D, lines 5, 6, and 8; and Part V, Section E, lines 2, 5, and 6. Also complete this part for any additional information. (See instructions).
| Facts And Circumstances Test |
|---|
| ORGANIZATION QUALIFIES AS A PUBLICLY SUPPORTED ORGANIZATION FOR 2020 BASED ON THE 2019 TAX FILING. SEE BELOW FACTS AND CIRCUMSTANCES EXPLANATION AS PROVIDED WITH THE 2019 TAX FILING. THE ORGANIZATION EXPECTS TO MEET THE PUBLIC SUPPORT TEST OF SECTION 509(A)(2) WITH THEIR 2021 TAX FILING. |
| Return Reference | Explanation |
|---|---|
| PART II LINE 17B | SCHEDULE A (FORM 990)-PART VI-SUPPLEMENTAL INFORMATION THE FOLLOWING IS IN RESPONSE TO QUESTION 17B OF PART II OF SCHEDULE A. SPECIFICALLY, THE FOLLOWING NARRATIVE SETS FORTH THE MANNER IN WHICH THE GREATER RENO COMMUNITY ICE SKATING ASSOCIATION (THE "TAXPAYER") SATISFIES THE REQUIREMENTS OF THE "10% FACTS AND CIRCUMSTANCES TEST." I. BACKGROUND. THE TAXPAYER WAS ESTABLISHED IN 2014 AS A NEVADA NONPROFIT CORPORATION. ALSO, IN 2014, THE TAXPAYER RECEIVED A DETERMINATION LETTER FROM THE INTERNAL REVENUE SERVICE TREATING IT AS (A) AN ORGANIZATION EXEMPT FROM FEDERAL INCOME TAXES UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED (THE "CODE"), AND (B) AN ORGANIZATION THAT QUALIFIES AS A PUBLIC CHARITY WITHIN THE MEANINGS OF CODE SECTIONS 509(A)(1) AND 170(B)(1)(A). THE SOLE PURPOSE OF THE TAXPAYER IS TO RAISE FUNDS FOR THE CONSTRUCTION, MAINTENANCE, AND OPERATION OF A HIGH QUALITY INDOOR ICE SKATING RINK (THE "ICE RINK") IN RENO, WASHOE COUNTY, NEVADA FOR THE USE OF YOUTHS AND ADULTS TO ENJOY YEAR-ROUND ICE SKATING ACTIVITIES, INCLUDING, WITHOUT LIMITATION, PUBLIC ICE SKATING SESSIONS, INSTRUCTIONAL ICE SKATING PROGRAMS, FIGURE SKATING, ICE HOCKEY, GROUP AND PRIVATE LESSONS, EXHIBITIONS, TOURNAMENT, AND COMPETITION. ALL PROGRAMS OF TAXPAYER WILL BE OPEN TO THE GENERAL PUBLIC AND BRING CULTURAL, RECREATIONAL, AND ENTERTAINMENT OPPORTUNITIES TO THE RENO/SPARKS, NEVADA AREA AND STRENGTHEN THE RECREATIONAL BASE OF THESE CITIES, AS WELL AS THE SURROUNDING AREAS, SUCH AS PORTIONS OF NORTHERN NEVADA AND NORTHERN CALIFORNIA. CURRENTLY, THE ICE RINK IS NEAR COMPLETION AND IT IS ANTICIPATED THAT THE ICE RINK WILL OPEN ON OR BEFORE DECEMBER 31, 2020. IN CONNECTION WITH THE OPERATION OF THE ICE RINK, TAXPAYER HAS RECEIVED SUBSTANTIAL SUPPORT FROM WASHOE COUNTY, NEVADA WHICH HAS ENTERED INTO A 20 YEAR GROUND LEASE WITH THE TAXPAYER, WHICH PROVIDES FOR ANNUAL LEASE PAYMENTS OF $1 PER YEAR. THE GROUND LEASE WITH WASHOE COUNTY, NEVADA ALSO GIVES THE TAXPAYER A 20 YEAR OPTION TO EXTEND THE GROUND LEASE. ACCORDINGLY, WASHOE COUNTY, NEVADA HAS ASSISTED TAXPAYER IN A MAJOR WAY BY CHARGING VIRTUALLY NO RENT FOR THE USE OF THE LAND ON WHICH THE ICE RINK IS LOCATED. ALTHOUGH THE TAXPAYER HAS CONTINUOUSLY OPERATED TO ATTRACT PUBLIC OR GOVERNMENTAL SUPPORT FOR THE CONSTRUCTION OF THE ICE RINK, MANY DONORS HAVE BEEN RELUCTANT TO MAKE CONTRIBUTIONS TO THE TAXPAYER UNTIL THE ICE RINK IS OPERATIONAL. THUS, A SUBSTANTIAL PERCENTAGE OF THE CONTRIBUTIONS TO COMPLETE THE CONSTRUCTION OF THE ICE RINK HAVE BEEN RAISED FROM A LIMITED NUMBER OF DONORS. HOWEVER, IT IS ANTICIPATED THAT ONCE THE ICE RINK IS OPERATIONAL, THAT TAXPAYER WILL RECEIVE SUBSTANTIAL DONATIONS FROM A BROAD CLASS OF DONORS, SUCH AS THE GENERAL PUBLIC, PUBLIC CHARITIES, AND GOVERNMENTAL UNITS. II. SATISFACTION OF 10% FACTS AND CIRCUMSTANCES TEST. IN GENERAL, THE TREASURY REGULATIONS TO CODE SECTION 170 PROVIDE THAT IF THE TAXPAYER'S PUBLIC SUPPORT FRACTION IS LESS THAN ONE-THIRD (1/3), BUT MORE THAN 10%, THE TAXPAYER MUST SATISFY THE "ATTRACTION OF PUBLIC SUPPORT" REQUIREMENT SET FORTH IN PARAGRAPH A. BELOW, AND THE "MULTI-FACTOR TEST" SET FORTH IN PARAGRAPH B. BELOW. IN THE PRESENT CASE, THE TAXPAYERS PUBLIC SUPPORT FRACTION FOR 2019 IS EQUAL TO 31.56%. THUS, IF THE TAXPAYER SATISFIES THE "ATTRACTION OF PUBLIC SUPPORT" TEST DESCRIBED IN PARAGRAPH A. BELOW AND THE MULTI FACTOR TEST DESCRIBED IN PARAGRAPH B. BELOW, IT WILL QUALIFY AS A PUBLIC CHARITY FOR THE TAXABLE YEARS 2019 AND 2020 UNDER CODE SECTIONS 509(A)(1) AND 170(B)(1)(A). A. ATTRACTION OF PUBLIC SUPPORT. THE "ATTRACTION OF PUBLIC SUPPORT" REQUIREMENT MAY BE SATISFIED IN ONE OR BOTH OF THE FOLLOWING WAYS: (1) THE TAXPAYER MAINTAINS A CONTINUOUS AND BONA FIDE PROGRAM FOR THE SOLICITATION OF FUNDS FROM THE GENERAL PUBLIC, COMMUNITY, OR MEMBERS OF THE TAXPAYER; AND/OR (2) THE ACTIVITIES CARRIED ON BY THE TAXPAYER ARE DESIGNED TO ATTRACT SUPPORT FROM GOVERNMENTAL UNITS OR OTHER PUBLIC CHARITIES. AS DISCUSSED BELOW, THE TAXPAYER SATISFIES BOTH OF THE FOREGOING REQUIREMENTS. FIRST, SINCE INCEPTION, THE TAXPAYER THROUGH ITS BOARD OF DIRECTORS, OFFICERS, VOLUNTEERS, AND ADVISORY BOARD HAS MAINTAINED A CONTINUOUS PROGRAM FOR THE SOLICITATION OF DONATIONS FROM THE GENERAL PUBLIC AND COMMUNITY. THESE ACTIVITIES HAVE INCLUDED, BUT ARE NOT LIMITED TO, SOLICITING DONATIONS PERSONALLY, BY LETTER, THROUGH THE TAXPAYER'S WEBSITE, AS WELL AS OTHER TYPES OF SOLICITATIONS. AS PREVIOUSLY DISCUSSED, SOME DONORS HAVE BEEN RELUCTANT TO MAKE DONATIONS TO THE TAXPAYER UNTIL THE ICE RINK IS COMPLETED AND OPEN TO THE PUBLIC. IN THIS REGARD, THE TAXPAYER BELIEVES THAT ONCE THE ICE RINK IS OPENED IN THE NEXT MONTH OR SO AND LOCALS AND VISITORS ARE ABLE TO USE THE ICE RINK, THAT DONATIONS FROM THE GENERAL PUBLIC, PUBLIC CHARITIES, AND POSSIBLY GOVERNMENT UNITS, WILL SUBSTANTIALLY INCREASE. BY WAY OF EXAMPLE, THE TAXPAYER HAS RECENTLY SOLICITED AND SECURED DONATIONS FROM MULTIPLE INDIVIDUALS AND BUSINESSES IN THE LOCAL COMMUNITY TO PROVIDE "QUALIFIED SPONSORSHIP DONATIONS" IN EXCHANGE FOR PLACING IN THE ICE RINK A BANNER WHICH LISTS THE NAME OF THE SPONSOR. MOST, IF NOT ALL, OF THESE POTENTIAL SPONSORS WERE RELUCTANT TO MAKE DONATIONS TO THE TAXPAYER PRIOR THE COMPLETION OF THE ICE RINK. ONCE THE ICE RINK IS OPENED, THE TAXPAYER WILL CONTINUE AND EXPAND ITS PROGRAM TO SOLICIT DONATIONS FROM THE GENERAL PUBLIC. AS A RESULT OF OPENING THE ICE RINK, THE TAXPAYER BELIEVES THAT ITS FUTURE DONATIONS FROM THE GENERAL PUBLIC AND THE LOCAL COMMUNITY WILL INCREASE SUBSTANTIALLY. SECOND, THE TAXPAYER HAS INSTITUTED A PROGRAM TO TARGET AND SOLICIT DONATIONS AND GRANTS FROM OTHER PUBLIC CHARITIES AND GOVERNMENTAL UNITS. WHEN THESE TYPES OF ENTITIES WERE APPROACHED FOR DONATIONS IN PRIOR YEARS, MANY WERE INTERESTED, BUT MOST WOULD NOT COMMIT TO DONATIONS UNTIL THE COMPLETION OF THE ICE RINK. WITH THE OPENING OF THE ICE RINK IN THE NEXT MONTH, TAXPAYER WILL REFOCUS ITS EFFORTS ON SOLICITING DONATIONS FROM PUBLIC CHARITIES AND GOVERNMENT UNITS. BASED UPON EARLY CONTACTS WITH THESE TYPES OF ENTITIES, TAXPAYER IS EXTREMELY OPTIMISTIC THAT MANY OF THOSE ENTITIES THAT WERE PREVIOUSLY APPROACHED, AS WELL AS OTHER PUBLIC CHARITIES THAT WILL BE APPROACHED IN THE NEAR FUTURE, WILL AGREE TO DONATE FUNDS TO THE TAXPAYER. BY WAY OF EXAMPLE, THE TAXPAYER RECENTLY SECURED A MULTI-YEAR DONATION FROM THE LOCAL HEART FOUNDATION, TO MAKE AN ANNUAL DONATION OF $50,000 OVER THE NEXT SEVERAL YEARS. BASED UPON THE FOREGOING, THE TAXPAYER CONTENDS THAT IT SATISFIES THE ABOVE "ATTRACTION OF PUBLIC SUPPORT" REQUIREMENT. B. MULTI-FACTOR TEST. IN ADDITION TO SATISFYING THE "ATTRACTION OF PUBLIC SUPPORT" TEST DISCUSSED ABOVE, THE TAXPAYER MUST SHOW THAT IT IS OPERATED AS A PUBLICLY SUPPORTED ORGANIZATION UNDER THE FOLLOWING APPLICABLE FIVE FACTORS. AS SET FORTH IN THE TREASURY REGULATIONS TO CODE SECTION 170, NOT ALL FIVE FACTORS ARE REQUIRED TO BE SATISFIED. INSTEAD, THE FACTORS RELEVANT TO EACH ORGANIZATION AND THE WEIGHT GIVEN TO EACH FACTOR MAY DIFFER, DEPENDING UPON THE NATURE OF THE ORGANIZATION AND THE LENGTH OF TIME THE ORGANIZATIONS HAVE BEEN IN EXISTENCE. THE FOLLOWING LISTS THE FIVE FACTORS LISTED IN THE TREASURY REGULATIONS AND EXPLAINS WHY THE TAXPAYER SATISFIES EACH FACTOR, OR IN CERTAIN CASES, WHY THE FACTOR IS NOT APPLICABLE TO THE TAXPAYER. 1. PERCENTAGE OF FINANCIAL SUPPORT. THIS FACTOR STATES THAT THE HIGHER THE ORGANIZATION'S PERCENTAGE OF PUBLIC SUPPORT ABOVE 10%, THE LESSER WILL BE THE BURDEN OF ESTABLISHING THE PUBLICLY SUPPORTED NATURE OF THE ORGANIZATION THROUGH THE OTHER FACTORS DISCUSSED BELOW. TAXPAYER'S RESPONSE. AS SET FORTH IN PART II, SECTION C, LINE 17A. OF SCHEDULE A TO TAXPAYER'S 2019 TAX RETURN, THE TAXPAYER'S PERCENTAGE OF PUBLIC SUPPORT FOR ITS TAXABLE YEAR 2019 IS 31.56%, WHICH IS AN EXTREMELY HIGH PERCENTAGE UNDER THE 10% FACTS AND CIRCUMSTANCE TEST. IN FACT, THE TAXPAYER'S PUBLIC SUPPORT PERCENTAGE IS JUST SHORT OF 33.33%, WHICH IF MET BY THE TAXPAYER, WOULD NOT REQUIRE THE TAXPAYER SATISFY THE 10% FACTS AND CIRCUMSTANCES TEST. GIVEN THAT TAXPAYER'S PUBLIC SUPPORT PERCENTAGE SUBSTANTIALLY EXCEEDS 10%, THIS FACTOR SHOULD BE GIVEN SUBSTANTIAL WEIGHT IN DETERMINING WHETHER THE TAXPAYER SATISFIES THE 10% FACTS AND CIRCUMSTANCES TEST AND THE OTHER FACTORS DISCUSSED BELOW SHOULD BE GIVEN LESSER WEIGHT. |
| PART II LINE 17B | 2. SOURCES OF SUPPORT. THIS FACTOR FOCUSES PRIMARILY ON WHETHER THE PUBLIC SUPPORT COMES FROM GOVERNMENT, OR A REPRESENTATIVE NUMBER OF PERSONS, RATHER THAN RECEIVING ALMOST ALL OF ITS SUPPORT FROM MEMBERS OF A SINGLE FAMILY. CONSIDERATION IS GIVEN TO THE TYPE AND AGE OF THE ORGANIZATION, AND TO WHETHER IT APPEALS TO A LIMITED CONSTITUENCY GEOGRAPHICALLY OR OTHERWISE. AS PREVIOUSLY MENTIONED IN SUBPARAGRAPH B.1. ABOVE, THE TAXPAYER'S PUBLIC SUPPORT PERCENTAGE IS 31.56% FOR THE TAXABLE YEAR 2019, WHICH INDICATES THAT A SUBSTANTIAL PERCENTAGE OF ITS SUPPORT WAS RECEIVED FROM A REPRESENTATIVE NUMBER OF PERSONS. IN ADDITION, IN 2020 TAXPAYER EXECUTED A GROUND LEASE WITH A GOVERNMENTAL ENTITY, WASHOE COUNTY, NEVADA, WHICH LEASES THE GROUND ON WHICH THE ICE RINK IS LOCATED TO TAXPAYER AT THE MINIMAL RENT OF $1 PER YEAR. AS PREVIOUSLY MENTIONED, THIS GROUND LEASE IS FOR A PERIOD OF 20 YEARS AND THE TAXPAYER HAS AN OPTION TO EXTEND THE TERM FOR AN ADDITIONAL 20 YEAR PERIOD. THUS, STARTING IN 2020 A SUBSTANTIAL AMOUNT OF TAXPAYER'S PUBLIC SUPPORT WILL BE RECEIVED FROM A GOVERNMENT UNIT, WASHOE COUNTY, NEVADA, IN THE FORM OF AN ALMOST FREE LEASE OF THE GROUND ON WHICH THE ICE RINK IS LOCATED. IN ADDITION, GIVEN THE SUBSTANTIAL COSTS TO CONSTRUCT THE ICE RINK AND THE FACT THAT MANY DONORS WERE RELUCTANT TO DONATE FUNDS UNTIL SUCH TIME AS THE ICE RINK IS COMPLETED, TAXPAYER HAD TO RELY ON A LIMITED NUMBER OF DONORS TO RAISE SUFFICIENT FUNDS TO CONSTRUCT THE ICE RINK. AS PREVIOUSLY MENTIONED, ONCE THE ICE RINK IS OPEN, TAXPAYER ANTICIPATES THAT GOVERNMENTAL UNITS AND A LARGE NUMBER OF INDIVIDUALS AND BUSINESSES IN THE RENO/SPARKS, NEVADA AREA WILL BE WILLING TO MAKE DONATIONS TO TAXPAYER IN THE FUTURE. MOREOVER, THE TAXPAYER CONTENDS THAT ITS OPERATION OF THE ICE RINK, ONCE OPENED, WILL APPEAL TO A LARGE CONSTITUENCY, WHICH INCLUDES THE RENO/SPARKS, NEVADA AREA, AS WELL AS AREAS LOCATED NEARBY, SUCH AS THE LAKE TAHOE AREA, THE CITIES OF CARSON CITY, GARDNERVILLE, MINDEN, FALLON, INCLINE, AND VARIOUS OTHER CITIES LOCATED IN NORTHERN NEVADA AND NORTHERN CALIFORNIA. 3. REPRESENTATIVE GOVERNING BOARD. THIS FACTOR REVIEWS WHETHER THE ORGANIZATION'S GOVERNING BODY REPRESENTS THE BROAD INTERESTS OF THE PUBLIC, OR THE PERSONAL OR PRIVATE INTERESTS OF A LIMITED NUMBER OF DONORS. BOARDS MEETING THIS FACTOR INCLUDE THOSE COMPRISED OF: (A) PUBLIC OFFICIALS ACTING IN THEIR OFFICIAL CAPACITIES, (B) PERSONS HAVING SPECIAL KNOWLEDGE OR EXPERTISE IN THE PARTICULAR FIELD OR DISCIPLINE IN WHICH THE ORGANIZATION IS OPERATING; (C) COMMUNITY LEADERS, SUCH AS ELECTED OR APPOINTED OFFICIALS, CLERGYMEN, EDUCATORS, CIVIC LEADERS, OR OTHER PERSONS REPRESENTING A BROAD CROSS-SECTION OF THE COMMUNITY VIEWS AND INTERESTS, AND (D) FOR MEMBERSHIP ORGANIZATIONS, INDIVIDUALS ELECTED BY A BROAD BASED MEMBERSHIP. TAXPAYER'S RESPONSE. TAXPAYER CURRENTLY HAS FOUR MEMBERS SERVING ON ITS BOARD OF DIRECTORS, WHOSE NAMES ARE JOEL GRACE ("JOEL"), CHRISTOPHER O'NEAL ("CHRIS"), JAMIE WINTER ("JAMIE"), AND CAMERON SORENSON ("CAM"). DURING THE TIME THAT THE ICE RINK WAS UNDER CONSTRUCTION, THE BOARD DETERMINED IT WAS IN THE BEST INTEREST OF THE TAXPAYER TO LIMIT THE NUMBER OF BOARD MEMBERS TO FOUR. TAXPAYER IS CURRENTLY CONSIDERING INCREASING ITS BOARD MEMBERS IN THE FUTURE. BELOW IS A SHORT BIOGRAPHY OF EACH OF THE CURRENT BOARD MEMBERS. JOEL GRACE. JOEL IS THE CHIEF OPERATING OFFICER AT RENO LAND, INC, A LARGE DEVELOPER IN THE RENO, NEVADA AREA. PREVIOUSLY, JOEL WORKED WITH UMPQUA BANK AND THE ECONOMIC DEVELOPMENT AUTHORITY OF WESTERN NEVADA (EDAWN). BORN AND RAISED IN NEW ENGLAND, JOEL GRADUATED FROM NEW HAMPSHIRE COLLEGE AND HOLDS AN MBA FROM THE UNIVERSITY OF SOUTHERN NEW HAMPSHIRE. JOEL MOVED TO NORTHERN NEVADA IN 2002. JOEL HAS EXTENSIVE VOLUNTEER EXPERIENCE WITH THE YMCA OF THE SIERRA, THE NORTHERN NEVADA CHILDREN'S CANCER FOUNDATION, AND THE JUNIOR ACHIEVEMENT ASSOCIATION. JOEL PLAYS SOCCER AND HOCKEY WEEKLY, AND COACHES KIDS' SPORTS. CAM SORENSON. CAM GREW UP IN CANADA AND HAS PARTICIPATED IN ORGANIZED HOCKEY PROGRAMS ACROSS NORTH AMERICA. PROFESSIONALLY, CAM BRINGS MORE THAN 25 YEARS OF LEADERSHIP AND BUSINESS DEVELOPMENT EXPERIENCE (MOST OF WHICH IS IN NORTHERN NEVADA) WORKING WITH SUCH WORLD CLASS COMPANIES AS STARBUCKS, INTUIT, AND BEST BUY. HE IS AN ACTIVE BOARD MEMBER WITH THE ECONOMIC DEVELOPMENT AUTHORITY OF WESTERN NEVADA (EDAWN) AND HAS ALSO VOLUNTEERED WITH SIERRA INLINE HOCKEY LEAGUE AND THE SOCIETY OF HUMAN RESOURCE MANAGERS. IN ADDITION, CAM HAS EXTENSIVE YOUTH PROGRAM COACHING EXPERIENCE, 10 YEARS WITH THE AMERICAN YOUTH SOCCER ORGANIZATION AND 15 YEARS WITH YOUTH HOCKEY. CHRIS O'NEAL. CHRIS IS A LOCAL ENTREPRENEUR, CURRENTLY ACTING AS THE CEO OF JOCHCO INVESTMENTS, LLC. JOCHCO INVESTMENTS OWNS A NUMBER OF LOCAL BUSINESSES INCLUDING THE JOINT CHIROPRACTIC, SURGCENTER DEVELOPMENT, SIERRA NEVADA BIOSCIENCE, AND MODERN ACUPUNCTURE. CHRIS RECEIVED HIS BA IN PHILOSOPHY FROM THE UNIVERSITY OF CALIFORNIA. SANTA BARBARA IN 2003, AND IN 2010, HE MOVED TO NORTHERN NEVADA TO BE NEAR FAMILY. CHRIS AND HIS FAMILY ARE DONORS TO THE TAXPAYER. JAMIE WINTER. JAMIE IS THE SENIOR CORPORATE COUNSEL FOR RENOWN HEALTH, THE LARGEST HOSPITAL IN NORTHERN NEVADA, AND HOMETOWN HEALTH, ONE OF THE LARGEST HEALTH INSURANCE PROVIDERS IN NORTHERN NEVADA, AND IS A GRADUATE OF THE UNIVERSITY OF CALIFORNIA, DAVIS SCHOOL OF LAW AND TRINITY COLLEGE. PRIOR TO HER CURRENT POSITION, JAMIE LITIGATED IN BOTH NEVADA AND CALIFORNIA WHILE PRACTICING LAW FOR TWO NEVADA-BASED LAW FIRMS. RAISED IN INCLINE VILLAGE, NEVADA, JAMIE GREW UP FIGURE SKATING COMPETITIVELY. AFTER A 13-YEAR COMPETITIVE CAREER, JAMIE WENT ON TO SKATE PROFESSIONALLY AROUND THE WORLD. JAMIE HAS SERVED IN VARIOUS BOARD POSITIONS INCLUDING INCLINE VILLAGE NURSERY SCHOOL, THE AMERICAN YOUTH SOCCER ORGANIZATION REGION 995, AND MOTHERS OFFERING MOTHERS SUPPORT (MOMS). ALL OF JAMIE'S THREE CHILDREN HAVE PLAYED HOCKEY AND ONE PLAYS COMPETITIVE MIDGET AA HOCKEY FOR THE GOLDEN STATE ELITE YOUTH TIER ICE HOCKEY PROGRAM IN NORTHERN CALIFORNIA. AS REFLECTED IN THE ABOVE BIOGRAPHIES OF THE TAXPAYER'S DIRECTORS, EACH ARE CIVIC AND COMMUNITY LEADERS IN THE RENO/SPARKS NEVADA COMMUNITY; EACH ARE BUSINESS LEADERS; MOST, IF NOT ALL, HAVE SUBSTANTIAL KNOWLEDGE IN THE FIELDS OF HOCKEY, SKATING, ETC. EITHER INDIVIDUALLY, OR THROUGH FAMILY MEMBERS; EACH HAVE BEEN INVOLVED IN VARIOUS CHARITIES AND/OR YOUTH ORGANIZATIONS, AND TOGETHER REPRESENT A BROAD CROSS-SECTION OF THE VIEWS AND INTERESTS IN THE RENO/SPARKS, NEVADA COMMUNITIES. IN ADDITION TO TAXPAYER'S BOARD OF DIRECTORS, THE TAXPAYER HAS AN ADVISORY BOARD OR COUNCIL THAT THE DIRECTORS CONFER WITH FROM TIME TO TIME ON VARIOUS MATTERS THAT PERTAIN TO THE TAXPAYER'S PROGRAMS AND OPERATIONS. THIS ADVISORY BOARD CONSISTS OF A BROAD CROSS-SECTION OF INDIVIDUALS IN THE RENO/SPARKS, NEVADA AREA, INCLUDING, WITHOUT LIMITATION, PUBLIC OFFICIALS, BUSINESS LEADERS, COMMUNITY LEADERS, CIVIC LEADERS, ENTREPRENEURS, AND INDIVIDUALS WITH KNOWLEDGE THAT PERTAIN TO SKATING AND TAXPAYER'S ACTIVITIES OF OPERATING THE ICE RINK. THE FOLLOWING IS A LIST OF THE INDIVIDUALS SERVING ON THE ADVISORY BOARD AND THEIR PRIMARY OCCUPATION. |
| PART II LINE 17B | NAMES AND PRIMARY OCCUPATION OF ADVISORY BOARD. SENATOR BEN KIECKHEFER MAYOR HILLARY SCHIEVE - CITY OF RENO, NEVADA COMMISSIONER BOB LUCEY - WASHOE COUNTY, NEVADA ALAN MAISS ANN SILVER- CEO, THE RENO - SPARKS CHAMBER OF COMMERCE CHEREE BOTELER - CHIEF MARKETING OFFICER, STEP2; MANAGING OWNER, OPPORTUNITY NEVADA ADAM KRAMER - EVP OF STRATEGY, SWITCH SHELLIE FINE - DIRECTOR OF SPORTS MANAGEMENT, RENO-SPARKS CONVENTION AND VISITORS AUTHORITY LAURA GALINDO - FORMER FIGURE SKATING CHAMPION DARRAH MARIE THORMAHLEN DR. DANIEL T. ROWAN - OPTOMETRIST, LASIK OF NEVADA JOANIE MALARCHUK - PSA MASTER RATED FIGURE SKATING AND POWER SKATING COACH MICKEY LANG - JUNIORS COACH AND FORMER AHL PLAYER RICHARD JAY - COMMISSIONER, NEVADA YOUTH SOCCER LEAGUE; VICE PRESIDENT, RENO YOUTH SPORTS ASSOCIATION; FIRST VICE PRESIDENT AND INVESTMENT OFFICER, MAJOR BROKERAGE FIRM CAROLE BRILL - MANAGING DIRECTOR, RMD NEVADA CHIP BOWLBY - MANAGING PARTNER, RENO LAND DEVELOPMENT COMPANY MIKE DRAPER - PARTNER, ARGENTUM PARTNERS DAVID HORTON - NEVADA DEPARTMENT OF CORRECTIONS JOHN TAYLOR - ETCETERA STEPHANIE LAMBOLEY SHERRY MORREY - NEVADA FIGURE SKATING CLUB/MORREY DISTRIBUTING COMPANY STEVEN A. MORROW, P.E. - FOUNDING PRINCIPAL, GEO-LOGIC ASSOCIATES; FOUNDER, HIGH SIERRA LACROSSE DENNIS NOLAN - EMS DIVISION CHIEF, RENO FIRE DEPARTMENT TOM REARDON - PRINCIPAL, TGR CONSULTING LAUREN SANKOVICH, CPA - PARTNER, EIDEBAILLY JEFF SUTICH - BUSINESS DEVELOPMENT ADVISER, NV ENERGY RICH WILLIAMSON - ATTORNEY, ROBERTSON, JOHNSON, MILLER & WILLIAMSON MATHEW WORK - ATTORNEY, WORK LAW LOUIE TRIO - PRESIDENT, NORTHERN NEVADA AMATEUR HOCKEY ASSOCIATION WILLIAM (BILL) JOHNSON - DIRECTOR OF OPERATIONS, SAVORY INVESTMENTS TASHA ANSON - VICE PRESIDENT, NN AMATEUR HOCKEY ASSOCIATION DENISE BARCOMB - FOUNDER, THE URBAN MARKET KAYA STANLEY - GENERAL COUNSEL, AXXCESS CAPITAL PARTNERS ANN MUDD - EDUCATION EXECUTIVE, APPLE RANDI REED - OWNER, HAUS OF REED CUSTOM FURNITURE THE TAXPAYER CONTENDS THAT ITS BOARD OF DIRECTORS MEETS THE REPRESENTATIVE GOVERNING BOARD TEST. MOREOVER, THE QUALIFICATIONS AND DIVERSITY OF THE TAXPAYER'S ADVISORY BOARD LISTED ABOVE SUBSTANTIALLY ENHANCES TAXPAYER'S ABILITY TO SATISFY SUCH TEST. 4. AVAILABILITY OF PUBLIC FACILITIES OR SERVICES; PUBLIC PARTICIPATION IN PROGRAMS OR POLICIES. THIS FACTOR CONSIDERS EVIDENCE THAT THE ORGANIZATION (A) PROVIDES FACILITIES OR SERVICES DIRECTLY FOR THE BENEFIT OF THE GENERAL PUBLIC, (B) PUBLISHES SCHOLARLY STUDIES THAT ARE WIDELY USED BY COLLEGES, UNIVERSITIES, OR MEMBERS OF THE PUBLIC, (C) CONDUCTS PROGRAMS PARTICIPATED IN OR SPONSORED BY PEOPLE HAVING SPECIAL KNOWLEDGE OR EXPERTISE, PUBLIC OFFICIALS, OR CIVIC OR COMMUNITY LEADERS, (D) MAINTAINS A DEFINITIVE COMMUNITY PROGRAM, SUCH AS SLUM CLEARANCE OR EMPLOYMENT DEVELOPMENT, OR (E) RECEIVES SIGNIFICANT FUNDS FROM GOVERNMENT OR A PUBLIC CHARITY TO WHICH IT IS CONTRACTUALLY ACCOUNTABLE. TAXPAYER'S RESPONSE. IT IS CLEAR THAT TAXPAYER'S ACTIVITIES CARRIED ON BY THE TAXPAYER OF CONSTRUCTING AND OPERATING AN ICE RINK IN THE RENO/SPARKS, NEVADA AREA THAT WILL BE OPEN TO THE GENERAL PUBLIC SATISFIES CLAUSE (A) ABOVE, WHICH REQUIRES TAXPAYER TO PROVIDE FACILITIES AND SERVICES FOR THE BENEFIT OF THE GENERAL PUBLIC ON A CONTINUING BASIS. TAXPAYER FURTHER CLAIMS THAT IT SATISFIES CLAUSE (C) ABOVE BY CONDUCTING PROGRAMS PARTICIPATED IN BY PEOPLE HAVING SPECIAL KNOWLEDGE OR EXPERTISE WITH THE PROGRAMS CARRIED ON BY TAXPAYER. IN PARTICULAR, TAXPAYER WILL CONDUCT SPECIALTY TEACHING PROGRAMS FOR THE GENERAL PUBLIC THAT PERTAIN TO HOCKEY, FIGURE SKATING, SPEED SKATING AND OTHER SKATING RELATED PROGRAMS. THESE PROGRAMS WILL BE IN ADDITION TO ALL OTHER PROGRAMS CARRIED ON BY TAXPAYERS. THE FOREGOING TEACHING PROGRAMS WILL BE SUPERVISED AND OVERSEEN BY INDIVIDUALS THAT HAVE SPECIAL KNOWLEDGE AND EXPERTISE IN THESE VARIOUS TEACHING PROGRAMS. TAXPAYER FURTHER CLAIMS THAT IT SATISFIES CLAUSE (D) ABOVE, RELATING TO THE MAINTENANCE OF A COMMUNITY PROGRAM. IN THIS REGARD, TAXPAYER IS THE ONLY ICE RINK IN THE RENO/SPARKS, NEVADA AREA. SINCE TAXPAYER'S PROGRAMS THAT WILL BE CARRIED ON AT THE ICE RINK WILL BE OPEN TO THE GENERAL PUBLIC, TAXPAYER WILL BE CARRYING ON A COMMUNITY PROGRAM THAT WILL BENEFIT THE RENO/SPARKS COMMUNITY THAT WAS NOT PREVIOUSLY AVAILABLE TO THE COMMUNITY PRIOR TO THE CONSTRUCTION OF THE ICE RINK. FURTHERMORE, TAXPAYER CONTENDS THAT IS ALSO SATISFIES THE REQUIREMENT SET FORTH IN CLAUSE (E) ABOVE WHICH RELATES TO TAXPAYER RECEIVING SIGNIFICANT FUNDS FROM A GOVERNMENTAL ENTITY. AS PREVIOUSLY DISCUSSED IN THIS NARRATIVE, TAXPAYER WILL BE RECEIVING SUBSTANTIAL SUPPORT FROM WASHOE COUNTY, NEVADA THROUGH A GROUND LEASE WITH THE TAXPAYER, WHICH PROVIDES FOR ANNUAL LEASE PAYMENTS OF $1 PER YEAR OVER THE 20 YEAR TERM OF SUCH LEASE. THIS LEASE FURTHER GIVES THE TAXPAYER THE RIGHT TO EXERCISE A 20 YEAR EXTENSION TO THE LEASE. IF TAXPAYER HAD ENTERED INTO A GROUND LEASE WITH NON-GOVERNMENTAL UNIT, TAXPAYER WOULD BE REQUIRED TO PAY THE FAIR MARKET RENTAL VALUE FOR SUCH GROUND LEASE WHICH WOULD BE SUBSTANTIAL. MOREOVER, TAXPAYER IS ACCOUNTABLE TO WASHOE COUNTY, NEVADA SINCE IT WILL BE REQUIRED TO COMPLY WITH THE TERMS AND CONDITIONS OF THE GROUND LEASE, INCLUDING COMPLIANCE OF ALL COVENANTS, REPRESENTATIONS AND WARRANTIES CONTAINED THEREIN. 5. ADDITIONAL FACTORS FOR MEMBERSHIP ORGANIZATIONS. THE TREASURY REGULATIONS TO CODE SECTION 170 INCLUDE ADDITIONAL FACTORS THAT ARE CONSIDERED WHEN THE ORGANIZATION IS A "MEMBERSHIP ORGANIZATION. SINCE TAXPAYER HAS NO MEMBERS, THESE REQUIREMENTS ARE NOT APPLICABLE TO THE TAXPAYER AND SHOULD NOT BE TAKEN INTO ACCOUNT WHEN DETERMINING IF THE TAXPAYER SATISFIES THE 10% FACTS AND CIRCUMSTANCE TEST. BASED UPON THE FOREGOING, TAXPAYER CONTENDS THAT IT CLEARLY SATISFIES THE 10% FACTS AND CIRCUMSTANCES TEST AND THEREFORE SHOULD BE TREATED AS A PUBLIC CHARITY UNDER CODE SECTIONS 509(A)(1) AND 170(B)(1)(A) FOR TAXPAYER'S TAXABLE YEARS 2019 AND 2020. |
Schedule A (Form 990 or 990-EZ) 2020
Additional Data
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| Software Version: |
Attach to Form 990 or 990-EZ.