Anclote Psychiatric Ctr. v. Commissioner
United States Tax Court
R examined the information returns of P, an organization exempt from Federal income tax. R concluded that P's exempt status should be revoked and informed P by letter of this conclusion. P submitted a written response to R in support of its continued exemption. Over 270 days thereafter, P filed a petition for declaratory judgment pursuant to sec. 7428, I.R.C., regarding its continuing tax-exempt status.
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R examined the information returns of P, an organization exempt from Federal income tax. R concluded that P's exempt status should be revoked and informed P by letter of this conclusion. P submitted a written response to R in support of its continued exemption. Over 270 days thereafter, P filed a petition for declaratory judgment pursuant to sec. 7428, I.R.C., regarding its continuing tax-exempt status. On the date P filed its petition, R had not issued a "proposed revocation" letter or a "final adverse determination" letter to P. R filed a motion to dismiss P's petition for lack of…
1Opinion of the Court
Anclote Psychiatric Center, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Anclote Psychiatric Ctr. v. Commissioner
Docket No. 19530-91X
United States Tax Court
98 T.C. 374; 1992 U.S. Tax Ct. LEXIS 30; 98 T.C. No. 28;
March 31, 1992, Filed
An appropriate order will be issued denying respondent's motion to dismiss for lack of jurisdiction.
R examined the information returns of P, an organization exempt from Federal income tax. R concluded that P's exempt status should be revoked and informed P by letter of this conclusion. P submitted a written response to R in support of its…
2Cases cited7 opinions
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- McKart v. United StatesSupreme Court of the United States · 1969
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- Prince Corp. v. CommissionerUnited States Tax Court · 1976
- High Adventure Ministries, Inc. v. CommissionerUnited States Tax Court · 1983
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