-4- Florida against the board of directors. Thereafter, the attorney general for the State of Florida sued the same board of directors on the theory that petitioner sold its assets to its board members for less than fair market value and, therefore, violated a Florida statute designed to prevent the improper use of any nonprofit corporation. The State and Federal court proceedings generated a vast amount of media coverage and publicity, and as a direct result thereof, a revenue agent employed in the exempt organization division of the IRS initiated an examination of petitioner in 1987. During this examination, respondent raised the issues of whether petitioner could continue to rely on the 1982 ruling letter and whether petitioner's tax-exempt status should be revoked. In a technical advice memorandum, issued to petitioner on April 29, 1991, the National Office determined that petitioner did not receive fair market value for the sale of its hospital facility and proposed to revoke its tax-exempt status. Respondent later issued a final adverse determination letter on December 12, 1991, revoking petitioner's status as an organization described in section 501(c)(3) effective for all years beginning on and after October 1, 1982. Simultaneously with the formal notice of revocation, respondent issued a notice of deficiency to petitioner for the taxable periods ending September 30, 1984 through September 30, 1988. Respondent made no determination with respect to petitioner's 1983 taxable yearPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011