T.C. Memo. 1999-304
UNITED STATES TAX COURT
WAYNE BASEBALL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15966-98X. Filed September 15, 1999.
John K. Graham and David J. Nagle, for petitioner.
Mark A. Ericson, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: Respondent determined that Wayne
Baseball, Inc. (petitioner), does not qualify as a section
501(c)(3) charitable organization and, therefore, is not exempt
from Federal taxation under section 501(a). Pursuant to section
7428 and title XXI of the Tax Court Rules of Practice and
Procedure, petitioner seeks a declaratory judgment that it is a
qualified organization under section 501(c)(3). The
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