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THORNTON, Judge: Petitioner brought this action for a
declaratory judgment, pursuant to section 7428 and Title XXI of
this Court's Rules. Petitioner requests the Court determine the
correctness of respondent’s adverse determination with respect to
its initial qualification as a tax-exempt organization under
section 501(c)(3).1 The parties have submitted this case fully
stipulated under Rule 122 on the basis of the pleadings and the
stipulated administrative record, which is incorporated herein by
this reference.
FINDINGS OF FACT
Petitioner is a California nonprofit public benefit
corporation with its principal place of business in Redlands,
California. It is a wholly owned subsidiary of Redlands Health
Systems, Inc. (RHS), a California nonprofit public benefit
corporation that has been recognized as exempt under section
501(c)(3) of the Code and as a public charity within the meaning
of section 509(a). RHS is the parent corporation of three
subsidiaries in addition to petitioner, namely Redlands Community
Hospital (Redlands Hospital) and Redlands Community Hospital
Foundation (Redlands Foundation), both of which are California
nonprofit public benefit corporations that have been recognized
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the time period
referred to. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011