Legal Opinion

International E22 Class Asso. v. Commissioner

United States Tax Court

Decided January 25, 1982No. Docket No. 16074-80XPublished

P, a yachting association, provided design and measurement tools in connection with its enforcement of amateur racing competition. Held, such provision does not constitute "the provision of athletic facilities or equipment" within the meaning of sec. 501(c)(3), I.R.C. 1954.

1Opinion of the Court

International E22 Class Association, Petitioner v. Commissioner of Internal Revenue, Respondent

International E22 Class Asso. v. Commissioner

Docket No. 16074-80X

United States Tax Court

78 T.C. 93; 1982 U.S. Tax Ct. LEXIS 145; 78 T.C. No. 7;

January 25, 1982, Filed

P, a yachting association, provided design and measurement tools in connection with its enforcement of amateur racing competition. Held, such provision does not constitute "the provision of athletic facilities or equipment" within the meaning of sec. 501(c)(3), I.R.C. 1954.

Michael J. Rufkahr, Mary F. Voce, and Paul J. Henry, for the…

2Cases cited6 opinions

  1. Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
  2. Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
  3. West Side Tennis Club v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
  4. Pittsburgh Press Club v. United StatesCourt of Appeals for the Third Circuit · 1976
  5. Maryland Country Club, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 1976

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