Legal Opinion

Abovo Foundation, Inc. v. Commissioner

United States Tax Court

Decided April 30, 2018No. 18673-15XUnpublished

1Opinion of the Court

T.C. Memo. 2018-57

UNITED STATES TAX COURT ABOVO FOUNDATION, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18673-15X. Filed April 30, 2018. Emmanuel C. Okonkwo (an officer), for petitioner. Marissa R. Lenius, for respondent. MEMORANDUM OPINION FOLEY, Judge: Pursuant to section 7428(a), petitioner seeks a declaratory judgment that it meets the requirements of section 501(c)(3) and is exempt from Federal income taxation. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to…

2Cases cited5 opinions

  1. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  2. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  3. Columbia Park & Recreation Asso. v. CommissionerUnited States Tax Court · 1987
  4. Indiana Crop Improv. Ass'n v. CommissionerUnited States Tax Court · 1981
  5. Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000

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