- 2 -
revoked petitioner’s tax-exempt status effective January 1,
1992.2 Petitioner has exhausted its administrative remedies and
has petitioned this Court to declare its qualification for
tax-exempt status under section 501(c)(3). See sec. 7428; see
also Rule 211(a), (b), (g). Following the parties’ filing with
the Court of the administrative record underlying respondent’s
determination, the Court’s granting of the parties’ joint motion
to calendar this case for trial, and the conclusion of the
ensuing trial, we decide whether respondent properly revoked
petitioner’s tax-exempt status under section 501(c)(3). We hold
that respondent did.
FINDINGS OF FACT
Some facts were stipulated and are so found. We incorporate
herein by this reference the parties’ stipulations of fact and
the exhibits submitted therewith. Petitioner is an association
that was formed by Larry Parr (Parr) on June 17, 1979. When its
petition for declaratory judgment was filed, petitioner’s
principal place of business was in Middletown, Ohio.
On August 3, 1982, respondent determined that petitioner was
a section 501(c)(3) organization exempt from Federal income tax.
The determination was effective as of the day of petitioner’s
formation. At the time of this determination, petitioner did not
2 Section references are to the applicable versions of the
Internal Revenue Code, Rule references are to the Tax Court Rules
of Practice and Procedure, and dollar amounts are rounded.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011