Rameses School of San Antonio, Texas - Page 1

                                 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