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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 year
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