AHW Corp. v. Commissioner
United States Tax Court
In its initial request for recognition as an organization exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954, petitioner proposed to engage in two types of activities -- the development of a housing project, and the provision of consulting and management services. Respondent issued a proposed adverse determination on the ground that providing the consulting and management services would cause petitioner to be not exempt.
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In its initial request for recognition as an organization exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954, petitioner proposed to engage in two types of activities -- the development of a housing project, and the provision of consulting and management services. Respondent issued a proposed adverse determination on the ground that providing the consulting and management services would cause petitioner to be not exempt. Petitioner then agreed not to provide such services, and it obtained a final determination that it was an organization described in sec. 501(c)(3), I.R.C. 1954.…
1Opinion of the Court
AHW Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
AHW Corp. v. Commissioner
Docket No. 28557-81X
United States Tax Court
79 T.C. 390; 1982 U.S. Tax Ct. LEXIS 47; 79 T.C. No. 23;
August 25, 1982, Filed
In its initial request for recognition as an organization exempt from Federal income tax under sec. 501(c)(3), I.R.C. 1954, petitioner proposed to engage in two types of activities -- the development of a housing project, and the provision of consulting and management services. Respondent issued a proposed adverse determination on the ground that providing the consulting and…
2Cases cited10 opinions
- Aetna Life Insurance v. HaworthSupreme Court of the United States · 1937
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- Thompson v. CommissionerUnited States Tax Court · 1978
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- New Community Senior Citizen Housing Corp. v. CommissionerUnited States Tax Court · 1979
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