Deer Park Country Club - Page 1

                                 T.C. Memo. 1995-567                                  

                               UNITED STATES TAX COURT                                

          DEER PARK COUNTRY CLUB, Petitioner v. COMMISSIONER                          
          OF INTERNAL REVENUE, Respondent                                             

          Docket No. 26210-93.           Filed November 28, 1995.                     

          John S. Elias, for petitioner.                                              
          William I. Miller, for respondent.                                          

                                 MEMORANDUM OPINION                                   

          HAMBLEN, Chief Judge:  Deer Park Country Club (petitioner)                  
          is a nonprofit Illinois corporation qualifying as a social club             
          that is exempt from taxation under section 501(c)(7).1                      
          Respondent determined a deficiency of $33,782 in petitioner's               
          Federal income tax liability for its taxable year ended October             

          1Unless otherwise indicated, section references are to the                  
          Internal Revenue Code as in effect for the year in issue.  Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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