- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011