T.C. Memo. 2007-85
UNITED STATES TAX COURT
RAMESES SCHOOL OF SAN ANTONIO, TEXAS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23228-04X. Filed April 10, 2007.
P was established as a nonprofit corporation under
the laws of the State of Texas for the purpose of
operating a school providing education to children in
the San Antonio area. P initially received recognition
from R as an organization described in sec. 501(c)(3),
I.R.C., which recognition R now seeks to revoke.
Held: P furthers private interests and therefore
is not operated exclusively for exempt charitable
and/or educational purposes. Consequently, P is not
entitled to exemption from income taxation under sec.
501(a), I.R.C., as an organization described in sec.
501(c)(3), I.R.C.
Victor L. Smith, for petitioner.
Michael K. Park and Virginia E. Cochran, for respondent.
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Last modified: November 10, 2007