- 4 - section 509(a) because they are organizations described in section 170(b)(1)(A)(ii). In short, they are orthodox Jewish day schools, and their students receive a complete dual curriculum in religious and secular studies. Both schools issue academic grades in their secular and religious education programs. During 1994, three of petitioners’ minor children attended Emek and one minor child attended Yeshiva Rav Isacsohn. The schools establish annually the amount of tuition for each student, payment of which is mandatory. There are also other mandatory payments for, inter alia, special events and application processing. Partial scholarships are provided for students with financial needs. Tuition payments are recorded as such in the schools’ books, and charitable contributions to the schools are recorded as “donations”. In the petition, petitioners makes no allegations in connection with the addition to tax for delinquency. In petitioners’ response to a motion for summary judgment filed by respondent and subsequently denied, petitioners state: The primary reason for filing after October 16, 1995, was lack of sufficient time to correctly prepare the return due to high work-related volume petitioner Michael Sklar, who is the petitioner knowledgeable in the taxable affairs of petitioners and regularly prepares petitioners’ returns. The reason this was not stated in the original petition is that petitioners felt that it was a moot point as, in the opinion of petitioners, there is no deficiency. Petitioners presented no further evidence on this issue.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011