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