Anclote Psychiatric Center, Inc. - Page 3

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                  If petitioner's tax-exempt status is revoked effective                                 
            October 1, 1982, we must decide whether petitioner is entitled to                            
            a net operating loss carryover from its fiscal year ended                                    
            September 30, 1983.                                                                          
                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are found                                   
            accordingly.  The stipulation of facts and the attached exhibits                             
            are incorporated herein by this reference.                                                   
                  Petitioner had its principal place of business in Tarpon                               
            Springs, Florida, at the time it filed its petition.  Petitioner                             
            filed its Federal Returns of Organization Exempt From Income Tax                             
            Under section 501(c) of the Internal Revenue Code (Forms 990) for                            
            the years in issue with the Atlanta Service Center, Atlanta,                                 
            Georgia.  For all relevant periods, petitioner used a fiscal year                            
            ending September 30.  Its reports on Form 990 reflected that                                 
            petitioner utilized the accrual method of accounting.                                        
                  Petitioner is a Florida corporation, organized under chapter                           
            617 of Florida Statutes as a corporation not-for-profit.                                     
            Petitioner was originally incorporated in 1951, as a for-profit                              
            corporation and, in December 1953, began operation of Anclote                                
            Manor Hospital (the hospital).  In 1958, petitioner became a                                 
            nonprofit corporation and received a determination letter that it                            
            qualified as a Federal tax-exempt corporation under section                                  
            501(c)(3).                                                                                   





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