Legal Opinion

Help Children, Inc. v. Commissioner

United States Tax Court

Decided August 30, 1957No. Docket No. 61955PublishedCited by 14 opinions

Held, petitioner, a nonprofit corporation, is not entitled to exemption from taxation for the years 1953 and 1954 under the provisions of section 101 (6), I. R. C. 1939, and section 501 (c) (3), I. R. C. 1954.

1Opinion of the Court

OPINION.

LeMire, Judge:

This proceeding involves deficiencies in income tax of petitioner for the years 1953 and 1954 in the amounts of $990.10 and $1,032.24, respectively.

The only issue is whether petitioner is entitled to exemption from taxation as a corporation organized and operated exclusively for charitable purposes.

All the facts have been stipulated, are so found, and are incorporated herein by reference.

Petitioner is an Ohio corporation having its principal office at Dayton, Ohio. It filed corporation income tax returns for the periods involved with the district director of internal…

2Cases cited2 opinions

  1. United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
  2. Ralph H. Eaton Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955

3Cited by14 opinions

  1. Smith-Dodd Businessman's Asso. v. CommissionerUnited States Tax Court · 1975
  2. Greater United Navajo Dev. Enters. v. CommissionerUnited States Tax Court · 1980
  3. P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
  4. Waco Lodge No. 166, Benevolent & Protective Order of Elks v. CommissionerUnited States Tax Court · 1981
  5. Golden Rule Church Ass'n v. CommissionerUnited States Tax Court · 1964

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