Chapman Glen Ltd. v. Commissioner
United States Tax Court
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 one of P's officers.
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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 one of P's officers. In 2009, three years after P consented to R's revocation of P's tax-exempt status effective Jan. 1, 2002, R determined that (1) P's election was…
1Opinion of the Court
Wherry, Judge:
These cases are consolidated for purposes of trial, briefing, and opinion. Petitioner petitioned the Court in docket No. 29527-07L to review the Internal Revenue Service (IRS) Office of Appeals’ determination sústaining respondent’s proposed levy on petitioner’s property to collect $66,539 in additions to tax for 2004. The additions to tax relate to respondent’s determination that petitioner failed to timely file Forms 990, Return of Organization Exempt From Income Tax, and 990-T, Exempt Organization Business Income Tax Return (and proxy tax under section 6033(e)), for 2004 and…
2Cases cited73 opinions
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