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HOUSING PIONEERS, INC. v. C.I.R.

No. 93-70583.

49 F.3d 1395 (1995)

HOUSING PIONEERS, INC., Petitioner-Appellant, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 7, 1995.

Attorney(s) appearing for the Case

Jerry L. Harris, San Diego, CA, for petitioner-appellant.

Gary R. Allen, Linda Mosakowski, U.S. Dept. of Justice, Tax Div., Washington, DC, for respondent-appellee.

Before: BEEZER and NOONAN, Circuit Judges, and DAVID ALAN EZRA, District Judge.

OPINION

NOONAN, Circuit Judge:

Housing Pioneers, Inc. (Pioneers) appeals the decision of the Tax Court denying it section 501(c)(3) status. We affirm the judgment of the Tax Court.

FACTS

Pioneers was incorporated March 21, 1989 as a "nonprofit public benefit corporation" under California law. Its articles of incorporation announced its "specific purpose" to be "to provide innovative and...

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