Solutions Plus, Inc. - Page 2




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         grounds that:  (1) Petitioner was not organized exclusively for              
         exempt purposes; (2) petitioner was not operated exclusively for             
         exempt purposes; and (3) petitioner failed to establish that it              
         did not operate for a substantial nonexempt purpose.  Pursuant to            
         section 7428, petitioner seeks a declaratory judgment that                   
         respondent’s denial of its request for tax-exempt status was                 
         erroneous and that petitioner qualifies for tax-exempt status                
         under section 501(c)(3).  The matter is now before us on                     
         respondent’s Motion For Summary Judgment.                                    
                                     Background                                       
              Petitioner’s only involvement in this case has been to file             
         the petition and a designation of place of submission.  See Rules            
         211(a) and 212.  Thereafter, petitioner did not, or would not,               
         participate in stipulating to the administrative record, as                  
         defined in Rule 210(b)(12).  See Rule 217(a).  As a consequence,             
         respondent filed the entire administrative record, appropriately             
         certified as to its genuineness by an official authorized to act             
         for the Commissioner.  See Rule 217(b)(1).  The following is                 
         drawn from that record.                                                      







              1(...continued)                                                         
          references are to the Tax Court Rules of Practice and Procedure.            





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