South Community Association - Page 2

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          revoked petitioner’s tax-exempt status effective January 1,                 
          1992.2  Petitioner has exhausted its administrative remedies and            
          has petitioned this Court to declare its qualification for                  
          tax-exempt status under section 501(c)(3).  See sec. 7428; see              
          also Rule 211(a), (b), (g).  Following the parties’ filing with             
          the Court of the administrative record underlying respondent’s              
          determination, the Court’s granting of the parties’ joint motion            
          to calendar this case for trial, and the conclusion of the                  
          ensuing trial, we decide whether respondent properly revoked                
          petitioner’s tax-exempt status under section 501(c)(3).  We hold            
          that respondent did.                                                        
                                  FINDINGS OF FACT                                    
               Some facts were stipulated and are so found.  We incorporate           
          herein by this reference the parties’ stipulations of fact and              
          the exhibits submitted therewith.  Petitioner is an association             
          that was formed by Larry Parr (Parr) on June 17, 1979.  When its            
          petition for declaratory judgment was filed, petitioner’s                   
          principal place of business was in Middletown, Ohio.                        
               On August 3, 1982, respondent determined that petitioner was           
          a section 501(c)(3) organization exempt from Federal income tax.            
          The determination was effective as of the day of petitioner’s               
          formation.  At the time of this determination, petitioner did not           

               2 Section references are to the applicable versions of the             
          Internal Revenue Code, Rule references are to the Tax Court Rules           
          of Practice and Procedure, and dollar amounts are rounded.                  

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