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effect at the time of respondent's determination. The
issue for decision is whether respondent correctly
determined that petitioner is a private foundation as
defined by section 509(a), rather than a supporting
organization within the meaning of section 509(a)(3). The
narrow issue presented by this case is whether respondent
correctly determined that petitioner does not meet the
"integral part test" prescribed by section 1.509(a)-
4(i)(3), Income Tax Regs.
The parties submitted this case for decision without
trial in accordance with Rule 122. See Rule 217(b)(2). In
this opinion, all Rule references are to the Tax Court
Rules of Practice and Procedure. The stipulation of facts
and the accompanying exhibits filed by the parties are
hereby incorporated in this opinion.
On the basis of the record, we find that petitioner
exhausted the administrative remedies available to it
within the Internal Revenue Service and that the juris-
dictional requirements to maintain this action, enumerated
by Rule 210(c), are satisfied. At the time the petition
was filed on its behalf, petitioner's address was in
Baltimore, Maryland.
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