Abraham Lincoln Opportunity Foundation - Page 2




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               Respondent represents in respondent’s motion, and petitioner           
          agrees or does not dispute in petitioner’s response, (1) that               
          petitioner ceased all operations and dissolved under the laws of            
          the State of Colorado in 1995 and (2) that on March 5, 1999, when           
          the petition in this case was filed, all relevant periods of                
          limitations for any potential tax liability of petitioner and/or            
          its contributors had expired with respect to 1990 through 1994,             
          the years to which respondent’s notice of revocation issued on              
          December 7, 1998 (respondent’s notice of revocation) and that               
          petition relate.1  According to respondent, the two foregoing               
          undisputed factual allegations                                              
               clearly renders [sic] this case moot since any decision                
               rendered by this Court as to whether or not petitioner                 
               was an I.R.C. � 501(c)(3) organization during the                      
               period at issue will have no effect on past contribu-                  
               tions to petitioner and, “[s]ince petitioner has dis-                  
               solved itself, any questions concerning the future                     
               deductibility of contributions by its donors do not                    
               exist . . .  .”  National Republican Foundation, T.C.                  
               Memo. 1988-336.                                                        
                    9.  Accordingly, this case is moot and should be                  
               dismissed for lack of jurisdiction since there is no                   
               actual controversy with respect to any issue in the                    
               case.                                                                  
               With respect to the dissolution of petitioner under the laws           
          of the State of Colorado that petitioner concedes occurred in               
          1995, petitioner argues in petitioner’s response:                           


               1According to petitioner, there is no tax exposure to any-             
          one, either to petitioner or to any individual and corporate                
          donors to petitioner, resulting from respondent’s notice of                 
          revocation.                                                                 




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