High Adventure Ministries, Inc. v. Commissioner
United States Tax Court
Petitioner is a church which respondent has previously found to be exempt from taxation. In 1980, respondent sought to reexamine petitioner's exempt status. Respondent requested certain information from petitioner, warning that failure to provide such information might result in the revocation of petitioner's exemption. Petitioner refused to provide the information and in several letters requested that respondent cease his examination.
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Petitioner is a church which respondent has previously found to be exempt from taxation. In 1980, respondent sought to reexamine petitioner's exempt status. Respondent requested certain information from petitioner, warning that failure to provide such information might result in the revocation of petitioner's exemption. Petitioner refused to provide the information and in several letters requested that respondent cease his examination. Respondent neither ceased his examination nor issued a notice of proposed revocation of exemption. On Mar. 1, 1982, petitioner filed a petition in this Court…
1Opinion of the Court
OPINION
Nims, Judge:
Petitioner brought an action for a declaratory judgment pursuant to section 74281 and Rule 211 on the ground that respondent failed to make a determination with respect to petitioner’s continuing qualification as an organization exempt from taxation under section 501(a) and described in sections 501(c)(3) and 170(b)(1)(A). This case is before us on respondent’s motion to dismiss for lack of jurisdiction on the ground that petitioner did not request a redetermination of its qualification as an exempt organization or, alternatively, that petitioner has not exhausted its…
2Cases cited11 opinions
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Thompson v. CommissionerUnited States Tax Court · 1978
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- New Community Senior Citizen Housing Corp. v. CommissionerUnited States Tax Court · 1979
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- High Adventure Ministries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
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- Efco Tool Co. v. CommissionerUnited States Tax Court · 1983
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