T.C. Memo. 2004-12 UNITED STATES TAX COURT PEOPLES PRIZE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18658-02X. Filed January 15, 2004. Daniel L. Pfaff (President), for petitioner. Elizabeth Edwards and Michael Blumenfeld, for respondent. MEMORANDUM OPINION HAINES, Judge: Respondent determined that Peoples Prize does not qualify as an organization described in section 501(c)(3) and consequently is not exempt from Federal income tax under section 501(a). Petitioner challenged respondent’s determination by timely filing a petition for a declaratory judgment pursuant to section 7428(a) after exhausting its administrative remedies and satisfying jurisdictionalPage: 1 2 3 4 5 6 7 8 9 10 Next
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