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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’s
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