-2- Arthur Carson (an officer), for petitioner. Helen F. Rogers, for respondent. MEMORANDUM OPINION NIMS, Judge: Petitioner brought an action for a declaratory judgment pursuant to section 7428 and Rule 211 on the ground that respondent had failed to determine whether petitioner qualifies as an organization exempt from taxation under section 501(a), (c)(3) and (4). Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code. This case is before us on respondent’s motion to dismiss for lack of jurisdiction on the ground that petitioner did not exhaust its administrative remedies pursuant to section 7428(b)(2). This case is submitted for decision on a comprehensive stipulation of facts, which is incorporated herein by this reference. Background Petitioner, National Paralegal Inst. Coalition, was organized as a nonprofit corporation in Texas on March 29, 2001. On January 11, 2002, it submitted a Form 1023, Application for Recognition of Exemption Under Section 501(c)(3)(petitioner’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011