Giving Hearts, Inc. v. Commissioner

T.C. Memo. 2019-94

UNITED STATES TAX COURT GIVING HEARTS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18621-16X. Filed July 29, 2019. John J. Simon, for petitioner. William I. Miller and Laura A. Price, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GUY, Special Trial Judge: On May 26, 2016, respondent issued a final adverse determination letter to Giving Hearts, Inc. (petitioner), revoking its status -2- [*2] as an organization exempt from Federal income tax under section 501(a).1 The revocation is effective retroactively to January 1, 2010. Petitioner…