At Cost Services, Inc. - Page 1

                                 T.C. Memo. 2000-329                                  

                               UNITED STATES TAX COURT                                

                        AT COST SERVICES, INC., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13604-96X.                Filed October 25, 2000.           

               Matthew Marion Fondel (an officer), for petitioner.                    
               Joan Ronder Domike, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               COHEN, Judge:  Respondent determined that At Cost Services,            
          Inc., 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              

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