Anonymous v. Comm'r
United States Tax Court
R issued P a final adverse determination letter (First Revocation Letter), accompanied by an examination report, that revoked P's tax-exempt status under I.R.C. sec. 501(c)(3) retroactively to Date 1. Litigation ensued and was settled by a closing agreement. Pursuant to the closing agreement, P agreed not to contest revocation of its tax-exempt status for prior years and to make a lump-sum payment to satisfy its tax obligations for those years.
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R issued P a final adverse determination letter (First Revocation Letter), accompanied by an examination report, that revoked P's tax-exempt status under I.R.C. sec. 501(c)(3) retroactively to Date 1. Litigation ensued and was settled by a closing agreement. Pursuant to the closing agreement, P agreed not to contest revocation of its tax-exempt status for prior years and to make a lump-sum payment to satisfy its tax obligations for those years. R agreed to withdraw the First Revocation Letter, to consider P's new application for exempt status, and, after acting on that application, to issue a…
1Opinion of the Court
ANONYMOUS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Anonymous v. Comm'r
Docket No. 8256-12D.
United States Tax Court
145 T.C. 246; 2015 U.S. Tax Ct. LEXIS 50; 145 T.C. No. 10;
October 26, 2015, Filed
Decision will be entered for respondent.
R issued P a final adverse determination letter (First Revocation Letter), accompanied by an examination report, that revoked P's tax-exempt status under I.R.C. sec. 501(c)(3) retroactively to Date 1. Litigation ensued and was settled by a closing agreement. Pursuant to the closing agreement, P agreed not to contest revocation of its tax-exempt…
2Cases cited11 opinions
- Tax Analysts v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1997
- Kluger v. CommissionerUnited States Tax Court · 1984
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Cooper v. Comm'rUnited States Tax Court · 2010
- Harold J. Marks, A/K/A Haley Justin Van De Mark and Lea Marks, A/K/A Alanna Leigh Van De Mark v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1991
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