T.C. Memo. 2005-293
UNITED STATES TAX COURT
NATIONAL PARALEGAL INST. COALITION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22543-04X. Filed December 22, 2005.
P, a nonprofit corporation, filed two successive
applications with R for a determination of tax exempt
status, Form 1023, Application for Recognition of
Exemption under Section 501(c)(3) and Form 1024,
Application for Recognition of Exemption under Section
501(a). P seeks declaratory relief as to its
qualification for exemption based upon R’s failure to
make a determination.
Held: P failed to exhaust its administrative
remedies, a jurisdictional prerequisite to declaratory
proceedings in the Tax Court relating to the status of
an organization under sec. 501(c)(3), I.R.C., as
required by sec. 7428, I.R.C. Therefore, jurisdiction
of this Court is not available.
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