Legal Opinion

CRSO v. Comm'r

United States Tax Court

Decided April 30, 2007No. 11804-05XPublished

P is a nonprofit corporation. Its sole activity involves renting out its two parcels of debt-financed commercial real estate and distributing the profits to a sec. 501(c)(3), I.R.C., organization. P applied for tax exemption under sec. 501(c)(3), I.R.C.

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P is a nonprofit corporation. Its sole activity involves renting out its two parcels of debt-financed commercial real estate and distributing the profits to a sec. 501(c)(3), I.R.C., organization. P applied for tax exemption under sec. 501(c)(3), I.R.C. In 2003, R sent a final adverse determination letter to P at an incorrect address; P did not receive the letter until R sent it to P's counsel in 2005. P filed its petition within 90 days of receiving the final adverse determination letter. Held: Because R's initial, misdirected adverse determination letter was ineffective for purposes of…

1Opinion of the Court

CRSO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

CRSO v. Comm'r

No. 11804-05X

United States Tax Court

128 T.C. 153; 2007 U.S. Tax Ct. LEXIS 12; 128 T.C. No. 12;

April 30, 2007, Filed

P is a nonprofit corporation. Its sole activity involves renting out its two parcels of debt-financed commercial real estate and distributing the profits to a sec. 501(c)(3), I.R.C., organization.

P applied for tax exemption under sec. 501(c)(3), I.R.C. In 2003, R sent a final adverse determination letter to P at an incorrect address; P did not receive the letter until R sent it to P's counsel in 2005. P…

2Cases cited10 opinions

  1. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  2. Nancey Silvers v. Sony Pictures Entertainment, Inc.Court of Appeals for the Ninth Circuit · 2005
  3. Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
  4. Catterall v. CommissionerUnited States Tax Court · 1977
  5. Louis E. Roszkos and Vivian L. Roszkos v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988

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