The Internal Revenue Service and a federal District Court are justified in saying that an non-existent entity is not entitled to federal income tax exemption as a 501(c)(4) social welfare organization, the First Circuit Court of Appeals has held. The conclusion was reached in an appeal by a convicted tax evader who was trying to avoid having to personally pay $3.79 million in income taxes owed on money received from his creation and sale of health supplements. Daniel H. George, Jr., a self-taught chemist, created and sold herbal and chemical supplements from his home in Rockport, MA. He had a “core group” of followers who helped him hold retreats and sell his supplements. Between 1996 and...