Chapman Glen Limited v. Commissioner

140 T.C. No. 15

UNITED STATES TAX COURT CHAPMAN GLEN LIMITED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 29527-07L, 27479-09. Filed May 28, 2013. In 1998, P was a foreign insurance company that elected under I.R.C. sec. 953(d) to be treated as a domestic corporation for U.S. Federal income tax purposes. G signed the election in G’s reported capacity as P’s secretary. P also applied for and was granted tax- exempt status as an insurance company effective Jan. 1, 1998. For 2003, P filed a Form 990, Return of Organization Exempt From Income Tax, that was not signed by…