- 2 - Taxable Year Ended1 Deficiency Sept. 30, 1984 $159,008 Sept. 30, 1985 110,623 Sept. 30, 1986 75,490 Sept. 30, 1987 45,444 Sept. 30, 1988 62,041 Unless otherwise stated, all section references are to the Internal Revenue Code, as in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The primary issue for decision is whether petitioner's tax- exempt status should be revoked. This issue turns on the question whether petitioner's sale of its hospital in May 1983 was for less than fair market value, resulting in prohibited inurement within the meaning of section 501(c)(3). If we decide that there was no such inurement, we must decide whether petitioner's tax-exempt status should be revoked for failure to conduct exempt activities for its fiscal years ended September 30, 1985, and 1986. If we decide petitioner's tax-exempt status was properly revoked, then we must decide whether petitioner is entitled to deduct certain amounts as ordinary and necessary business expenses during the years for which its income is no longer tax- exempt. 1 The issuance of a notice of deficiency for the taxable year ended Sept. 30, 1983, is barred by the period of limitations.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