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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined that Rameses School of
San Antonio, Texas (petitioner), no longer qualified for
exemption from Federal income taxation under section 501(a) as an
organization meeting the requirements of section 501(c)(3).1
Respondent therefore revoked petitioner’s tax-exempt status
effective September 22, 1995. Petitioner challenged respondent’s
determination by timely invoking the jurisdiction of this Court
for a declaratory judgment pursuant to section 7428. In
accordance with Rule 217, the administrative record underlying
respondent’s determination was filed with the Court, and a
subsequent trial was conducted. At this juncture, the issue for
decision is whether petitioner is operated exclusively for exempt
purposes (i.e., educational and/or charitable) within the meaning
of section 501(c)(3).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986, as amended, and Rule references
are to the Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007