Legal Opinion
CRSO v. Commissioner
United States Tax Court
Decided April 30, 2007No. 11804-05XUnknown
1Opinion of the Court
128 T.C. No. 12
UNITED STATES TAX COURT CRSO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11804-05X. Filed April 30, 2007. P is a nonprofit corporation. Its sole activity involves renting out its two parcels of debt-financed commercial real estate and distributing the profits to a sec. 501(c)(3), I.R.C., organization. P applied for tax exemption under sec. 501(c)(3), I.R.C. In 2003, R sent a final adverse determination letter to P at an incorrect address; P did not receive the letter until R sent it to P’s counsel in 2005. P filed its petition within 90 days of…
2Cases cited10 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Walter F. Vorbleski and Florence Vorbleski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Catterall v. CommissionerUnited States Tax Court · 1977
- Dominic A. Esposito, Guardian of the Estate of David J. McClintock Jr., a Minor v. Ralph Emery and Cecil SpencerCourt of Appeals for the Third Circuit · 1968
- Louis E. Roszkos and Vivian L. Roszkos v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
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