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CONDINGTON COUNTY HUMANE SOCIETY v. COMMISSIONER

Docket No. 21539-89X.

61 T.C.M. 2496 (1990)

T.C. Memo. 1991-186

Codington County Humane Society v. Commissioner.

United States Tax Court.

Filed April 29, 1991.

Attorney(s) appearing for the Case

J. Douglas Austin and Alan L. Austin, 25 First Ave., Watertown, S.D., for the petitioner. William I. Miller, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

The issue for decision is whether respondent abused his discretion in denying petitioner's application for an extension of time to file an amended application in which it sought retroactive recognition as a tax exempt organization under section 501(c)(3)1, from the date of its incorporation on August 15, 1977, to August 3, 1988, the effective date of respondent's recognition of such tax-exempt...

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