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exemption from Federal income taxation pursuant to section
501(a). The revocation was retroactive to January 1, 1987.
Unless otherwise indicated, section references are to sections of
the Internal Revenue Code, as amended, and Rule references are to
the Tax Court Rules of Practice and Procedure.
Respondent revoked petitioner’s tax-exempt status under
section 501(c)(3) on the grounds that: (1) Petitioner was not
operated exclusively for a tax-exempt purpose; and (2)
petitioner’s activities were tantamount to providing commercial-
type insurance within the meaning of section 501(m)(1).
Petitioner filed a timely petition for declaratory judgment
pursuant to section 7428(a) challenging respondent’s
determination letter. At the time the petition was filed,
petitioner’s principal place of business was in Salt Lake City,
Utah.
The administrative record was submitted to the Court
pursuant to Rule 217(b)(1). The facts contained in the
administrative record are assumed to be true for purposes of this
proceeding. See Rule 217(b)(1). The case was submitted to the
Court by joint motion of the parties pursuant to Rule 122. The
parties also filed a stipulation of facts with attached exhibits.
The parties agree that petitioner has satisfied all
jurisdictional requirements. See sec. 7428(b); Rule 210(c).
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Last modified: May 25, 2011