Anclote Psychiatric Center, Inc. - Page 2

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                        Taxable Year Ended1            Deficiency                                        
                        Sept. 30, 1984                 $159,008                                          
                       Sept. 30, 1985                 110,623                                           
                        Sept. 30, 1986                 75,490                                            
                        Sept. 30, 1987                 45,444                                            
                        Sept. 30, 1988                 62,041                                            
                  Unless otherwise stated, all section references are to the                             
            Internal Revenue Code, as in effect for the years in issue, and                              
            all Rule references are to the Tax Court Rules of Practice and                               
            Procedure.                                                                                   
                  The primary issue for decision is whether petitioner's tax-                            
            exempt status should be revoked.  This issue turns on the                                    
            question whether petitioner's sale of its hospital in May 1983                               
            was for less than fair market value, resulting in prohibited                                 
            inurement within the meaning of section 501(c)(3).  If we decide                             
            that there was no such inurement, we must decide whether                                     
            petitioner's tax-exempt status should be revoked for failure to                              
            conduct exempt activities for its fiscal years ended                                         
            September 30, 1985, and 1986.                                                                
                  If we decide petitioner's tax-exempt status was properly                               
            revoked, then we must decide whether petitioner is entitled to                               
            deduct certain amounts as ordinary and necessary business                                    
            expenses during the years for which its income is no longer tax-                             
            exempt.                                                                                      

                  1  The issuance of a notice of deficiency for the taxable                              
            year ended Sept. 30, 1983, is barred by the period of                                        
            limitations.                                                                                 




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