- 2 - 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. OPINION 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). Background Petitioner 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007