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…
Read the full summary
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
OPINION
Chabot, Judge:
This matter is before us on petitioner’s motion for summary judgment pursuant to Rule 121.1
Petitioner initiated this action pursuant to section 74282 for a declaratory judgment that it qualifies as an organization described in section 501(c)(3) which is exempt from tax under section 501(a) and that it qualifies as an organization described in section 170(c)(2). The action was initiated after respondent revoked a favorable ruling letter which had been issued to petitioner. The revocation issued November 2, 1990, is retroactive to June 11, 1984. The issue for decision is…
2Cases cited27 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
22 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- United Cancer Council v. CommissionerUnited States Tax Court · 1997
- United Cancer Council v. CommissionerUnited States Tax Court · 1997
- United Cancer Council, Inc. v. CommissionerUnited States Tax Court · 1997
- United Cancer Council, Inc. v. CommissionerUnited States Tax Court · 1993