Christie E. Cuddeback and Lucille M. Cuddeback Memorial Fund - Page 2




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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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