T.C. Memo. 2005-30
UNITED STATES TAX COURT
AMEND16ROBERTWIRENGARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18437-03X. Filed February 22, 2005.
R.O. Wirengard (an officer), for petitioner.
Helen F. Rogers, for respondent.
MEMORANDUM OPINION
WELLS, Judge: In a final adverse determination letter,
respondent determined that petitioner did not qualify for
exemption from Federal income taxation pursuant to section 501(a)
as an organization described in section 501(c)(3).1 Having
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
(continued...)
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