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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
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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Last modified: November 10, 2007