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Held: P furthers private interests and therefore is
not operated exclusively for exempt charitable purposes.
Consequently, P is not entitled to exemption from income
taxation under sec. 501(a), I.R.C., as an organization
described in sec. 501(c)(3), I.R.C.
James A. Nitsche, for petitioner.
Joan Ronder Domike, for respondent.
OPINION
NIMS, Judge: Respondent determined that petitioner Quality
Auditing Company, Inc., does not qualify for exemption from
Federal income taxation under section 501(a) as an organization
meeting the requirements of section 501(c)(3). Having exhausted
its administrative remedies, petitioner challenged respondent’s
determination by timely invoking the jurisdiction of this Court
for a declaratory judgment pursuant to section 7428(a). The case
was submitted for decision under Rule 122 upon the stipulated
administrative record. For purposes of this proceeding, the
facts and representations contained in the administrative record
are accepted as true, see Rule 217(b), and are incorporated
herein by this reference. The issue for decision is whether
petitioner is operated exclusively for charitable purposes within
the meaning of section 501(c)(3).
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011