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 underPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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