-2-
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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