-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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011