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 jurisdictional
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