United Cancer Council, Inc. v. Commissioner
United States Tax Court
In a ruling letter dated March 31, 1969, respondent ruled that petitioner was exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954. On November 2, 1990, respondent revoked the favorable ruling letter retroactive to June 11, 1984, and also issued a notice of deficiency with respect to petitioner's income tax for 1986 and 1987. Petitioner then initiated the instant action pursuant to sec. 7428, I.R.C. 1986, for a declaratory judgment that it qualifies as an…
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In a ruling letter dated March 31, 1969, respondent ruled that petitioner was exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954. On November 2, 1990, respondent revoked the favorable ruling letter retroactive to June 11, 1984, and also issued a notice of deficiency with respect to petitioner's income tax for 1986 and 1987. Petitioner then initiated the instant action pursuant to sec. 7428, I.R.C. 1986, for a declaratory judgment that it qualifies as an organization under sec. 501(c)(3) which is exempt from Federal income tax under sec. 501(a) and that it qualifies as an…
1Opinion of the Court
UNITED CANCER COUNCIL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
United Cancer Council, Inc. v. Commissioner
Docket No. 2008-91X
United States Tax Court
100 T.C. 162; 1993 U.S. Tax Ct. LEXIS 11; 100 T.C. No. 11;
March 11, 1993, Filed
An appropriate order will be issued, denying petitioner's motion for summary judgment.
In a ruling letter dated March 31, 1969, respondent ruled that petitioner was exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954. On November 2, 1990, respondent revoked the favorable ruling letter retroactive to June 11, 1984, and also issued a…
2Cases cited28 opinions
- Mathews v. EldridgeSupreme Court of the United States · 1976
- Board of Regents of State Colleges v. RothSupreme Court of the United States · 1972
- Morrissey v. BrewerSupreme Court of the United States · 1972
- Cleveland Board of Education v. LoudermillSupreme Court of the United States · 1985
- Goldberg v. KellySupreme Court of the United States · 1970
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