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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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