Senate Report No. 94-938
United States Senate
94th Cong. 2d Sess. 585-591 (1976)
- Written by Daniel Clark, JD
Facts
Taxpayers had limited options to contest the denial or withdrawal of tax-exempt status from the Internal Revenue Service (IRS). Generally, the way to seek judicial review of an IRS denial was to flaunt the IRS’s ruling, be assessed a tax deficiency by the IRS, and then challenge the deficiency in court and argue that the deficiency was attributable to an erroneous determination that the plaintiff was taxable. Congress enacted § 7428 of the Internal Revenue Code (code) to make it easier for organizations to seek review of the IRS’s determinations as to the organizations’ tax-exempt statuses. The Senate Finance Committee issued a report explaining § 7428.
Rule of Law
Issue
Holding and Reasoning ()
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