Houston Lawyer Referral Service, Inc. v. Commissioner
United States Tax Court
Petitioner's representatives are alleged to have orally furnished additional information to Internal Revenue Service representatives at conferences relating to petitioner's application for exempt status under sec. 501(c)(3), I.R.C. 1954. Such orally furnished information was not reduced to writing or included in any of the documents comprising the administrative record.
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Petitioner's representatives are alleged to have orally furnished additional information to Internal Revenue Service representatives at conferences relating to petitioner's application for exempt status under sec. 501(c)(3), I.R.C. 1954. Such orally furnished information was not reduced to writing or included in any of the documents comprising the administrative record. Held, in an action for declaratory judgment under sec. 7428, I.R.C. 1954, petitioner's failure to submit the additional information in writing does not constitute "good cause," within the meaning of Rule 217(a) of the Rules of…
1Opinion of the Court
OPINION
Featherston, Jvdge:
In this action under section 74281 for a declaratory judgment that petitioner is entitled to exemption from Federal income taxes under section 501(c)(3), petitioner has filed a Motion to Present Evidence Not Contained in the Administrative Record. Respondent objects on the ground that “good cause” within the meaning of Rule 217(a)2 has not been shown for the presentation of such evidence. We agree with respondent that petitioner’s motion must be denied.
Section 7428(a)3 confers jurisdiction on this Court to “make a declaration” with respect to the “initial…
2Cases cited2 opinions
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Alexander v. "Americans United" Inc.Supreme Court of the United States · 1974
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- Church in Boston v. CommissionerUnited States Tax Court · 1978
- General Conference of Free Church v. CommissionerUnited States Tax Court · 1979
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Est of Hawaii v. CommissionerUnited States Tax Court · 1979
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