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               charitable or other exempt purposes within the meaning                 
               of sec. 501(c)(3), I.R.C.                                              

               James J. Workland and Gary C. Randall, for petitioner.                 
               Mark A. Weiner, for respondent.                                        

               THORNTON, Judge:  Respondent denied petitioner’s request for           
          tax-exempt status under section 501(c)(3).1  Pursuant to section            
          7428, petitioner seeks declaratory relief.                                  
               The parties submitted this case to the Court without trial             
          to be decided on the basis of the pleadings and the parties’                
          stipulation as to the administrative record.  See Rules 122,                
          217(b).  The Court’s decision will be based upon the assumption             
          that the facts as represented in the administrative record, as              
          stipulated, are true.  See Rule 217(b).                                     
               On December 26, 2000, petitioner was incorporated in the               
          State of Washington as a nonprofit corporation.  When it filed              
          its petition, petitioner’s principal place of business was in               
          Spokane, Washington.                                                        

               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code, as amended; Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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