Legal Opinion
The Hope School v. United States
Court of Appeals for the Seventh Circuit
Decided January 2, 1980No. 79-1239PublishedCited by 24 opinions
1Opinion of the Court
SPRECHER, Circuit Judge.
The issue raised in this appeal is whether a tax-exempt organization’s solicitation of contributions through the mailing of greeting cards to potential contributors constitutes an unrelated trade or business within the meaning of sections 511-13 of the Internal Revenue Code. We hold that it does not and reverse the judgment below.
I
The Hope School is a non-profit charitable and educational organization exempt from federal income tax under 26 U.S.C. § 501(c)(3). For the tax years 1968 through 1970, the Commissioner assessed against the School an unrelated business income…
2Cases cited11 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- United States v. PyneSupreme Court of the United States · 1941
6 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Disabled American Veterans v. United StatesUnited States Court of Claims · 1981
- Louisiana Credit Union League v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1982
- Groetzinger v. CommissionerUnited States Tax Court · 1984
- Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
- Carolinas Farm & Power Equipment Dealers Association, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1983
19 more not listed; retrieve them via the Exa API.