T.C. Memo. 2002-275
UNITED STATES TAX COURT
SALVATION NAVY, INC., Petitioner v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 7013-01X. Filed October 30, 2002.
Based upon the facts contained in the
administrative record, Held: Petitioner is not
operated as an organization entitled to exemption under
sec. 501(c)(3), I.R.C.
David A. Valfer (an officer), for petitioner.
Linda P. Azmon, for respondent.
MEMORANDUM OPINION
NIMS, Judge: Respondent determined that petitioner
Salvation Navy, Inc. (SNI), does not qualify as a section
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