T.C. Memo. 2000-318
UNITED STATES TAX COURT
THE NATIONALIST FOUNDATION, A MISSISSIPPI NON-PROFIT CORPORATION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14871-98X. Filed October 11, 2000.
Richard Barrett, for petitioner.
Joan Ronder Domike, for respondent.
MEMORANDUM OPINION
COHEN, Judge: Respondent determined that The Nationalist
Foundation (petitioner) 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 section 501(c)(3). The issues for decision
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