Creditguard of Am. v. Comm'r

149 T.C. No. 17, 2017 U.S. Tax Ct. LEXIS 52
CourtUnited States Tax Court
DecidedOctober 10, 2017
DocketDocket No. 1332-16L
StatusPublished

This text of 149 T.C. No. 17 (Creditguard of Am. v. Comm'r) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Creditguard of Am. v. Comm'r, 149 T.C. No. 17, 2017 U.S. Tax Ct. LEXIS 52 (tax 2017).

Opinion

CREDITGUARD OF AMERICA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Creditguard of Am. v. Comm'r
Docket No. 1332-16L
United States Tax Court
2017 U.S. Tax Ct. LEXIS 52; 149 T.C. No. 17;
October 10, 2017, Filed

An appropriate order and decision will be entered.

R revoked P's tax-exempt status retroactively to Jan. 1, 2002. In a subsequent deficiency proceeding P executed a stipulated decision document, agreeing to assessment of a deficiency for its 2002 tax year and of underpayment interest on that deficiency "as provided by law."

R accrued and assessed interest on the deficiency from the date on which P's 2002 corporate tax return would have been due. When that amount remained unpaid, R began collection action. In a collection due process proceeding, P disputed its underlying liability, arguing that interest can begin accruing no earlier than the date on which R issued the final determination revoking P's tax-exempt status, notwithstanding the retroactive character of that revocation.

1. Held: Retroactive revocation of P's tax-exempt status requires restoring R to the position R would have occupied if P had never enjoyed tax-exempt status during its 2002 tax year.

2. Held, further, P is liable for interest beginning on the date its 2002 corporate tax return would have been due.

3. Held, further, the SO did not abuse his discretion in sustaining the proposed collection action.

*52 Matthew T. Journy and Carrie Garber Siegrist, for petitioner.
Scott A. Hovey, for respondent.
LAUBER, Judge.

LAUBER

LAUBER, Judge: In this collection due process (CDP) case petitioner seeks review pursuant to sections 6320 and 6330(d)(1)1 of the determination by the Internal Revenue Service (IRS or respondent) to uphold a notice of Federal tax lien (NFTL) filing. The parties have filed under Rule 121 cross-motions for summary judgment presenting what seems to be a question of first impression in this Court. That question concerns the proper computation of interest on a tax deficiency where the IRS has retroactively revoked a corporation's tax-exempt status under section 501(a) and (c)(3).

The IRS revoked petitioner's tax-exempt status in 2012, made the revocation retroactive to January 1, 2002, and eventually issued it a notice of deficiency for that year. Petitioner timely petitioned this Court and, on November 30, 2012, we entered a stipulated decision in that case. Our decision determined a deficiency of $216,547 in petitioner's Federal income tax for 2002. The parties included a below-the-line stipulation that underpayment interest would later be assessed "as provided by law."

Upon revocation of its tax-exempt status, petitioner became*53 obligated to file Form 1120, U.S. Corporation Income Tax Return, for 2002. Respondent contends that the starting date for computing interest on the deficiency is determined by reference to the date prescribed by law for filing a Form 1120 for 2002 by a corporation that uses the calendar taxable year, which in this case would be March 17, 2003. Petitioner contends that the starting date for computing interest is February 1, 2012, the date on which the IRS issued the final determination letter revoking its tax-exempt status. Concluding as we do that respondent has the better side of this argument, we will grant his motion for summary judgment, deny petitioner's cross-motion, and sustain the proposed collection action.

Background

The following facts are derived from the parties' pleadings and motion papers, including the attached declaration and exhibits. Petitioner had its principal place of business in Florida when it filed its petition.

Petitioner was incorporated in Florida in 1991 as a nonprofit corporation engaged principally in credit counseling. In December 1993 the IRS issued petitioner a favorable determination letter recognizing it as an organization exempt from Federal income*54 tax under section 501(a) and (c)(3). In May 2003 petitioner filed with the IRS, as required by section 6033(a)(1), an information return on Form 990, Return of Organization Exempt From Income Tax, for its 2002 calendar taxable year. Seesec. 6072(e).

In December 2003 the IRS commenced an examination of petitioner's Form 990 for 2002. At the conclusion of this examination and the ensuing administrative process, the IRS issued to petitioner, on February 1, 2012, a final adverse determination letter revoking its tax-exempt status retroactively to January 1, 2002. This letter informed petitioner: "You are required to file Federal income tax returns on Forms 1120 for the tax periods stated in the heading of this letter and for all tax years thereafter."

When petitioner did not promptly file a Form 1120 for 2002, the IRS prepared on its behalf a substitute for return (SFR) that met the requirements of section 6020(b). On June 6, 2012, on the basis of that SFR, the IRS issued petitioner a notice of deficiency, and in response petitioner timely petitioned this Court. See CreditGuard of Am., Inc. v. Commissioner, docket No. 21935-12 (filed Aug. 30, 2012).

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Cite This Page — Counsel Stack

Bluebook (online)
149 T.C. No. 17, 2017 U.S. Tax Ct. LEXIS 52, Counsel Stack Legal Research, https://law.counselstack.com/opinion/creditguard-of-am-v-commr-tax-2017.