2
Tax Court Rules of Practice and Procedure, except as otherwise
noted.
At the time of filing the petition herein, petitioner was
located in Leggett, California.
Respondent having filed with her answer herein the index of
the administrative record, under Rule 213(a)(3), and the parties
having stipulated the full administrative record, the case is to
be decided on the basis of such administrative record, Rule 217.
By stipulation of the parties, the case was submitted under Rule
122. As specified in Rule 210(c), the Court has jurisdiction of
this action for declaratory judgment in that respondent has
issued an adverse determination as to petitioner's qualification
for exemption under section 501(c)(3); petitioner organization
was in existence at the time this action was brought; this
petition was brought within the time limits of section
7428(b)(3); and respondent has conceded that petitioner has
exhausted available administrative remedies. The facts found
herein are those in the administrative record as stipulated by
the parties. Rule 217(b)(1).
Petitioner is an unincorporated association organized on
July 8, 1992. Its articles of organization were submitted and
signed by John Stahl as founder, and he, together with two other
individuals, became the initial trustees and the governing body
of petitioner. The organizational documents provide for "project
communities" at various places, each of which will elect a
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