Legal Opinion

United Cancer Council v. Commissioner

United States Tax Court

Decided December 2, 1997No. Tax Ct. Dkt. No. 2008-91XPublished

Petitioner was organized in 1963. In a ruling letter dated Mar. 31, 1969, respondent ruled that petitioner was exempt from Federal income tax and was an eligible charitable donee. Secs. 501(a), 501(c)(3), 170(c), I.R.C. 1954. On June 11, 1984, petitioner entered into a 5-year fundraising contract (the Contract) with a professional fundraiser (W&H). During 1984 through 1989, W&H helped petitioner conduct a nationwide direct mail fundraising campaign.

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Petitioner was organized in 1963. In a ruling letter dated Mar. 31, 1969, respondent ruled that petitioner was exempt from Federal income tax and was an eligible charitable donee. Secs. 501(a), 501(c)(3), 170(c), I.R.C. 1954. On June 11, 1984, petitioner entered into a 5-year fundraising contract (the Contract) with a professional fundraiser (W&H). During 1984 through 1989, W&H helped petitioner conduct a nationwide direct mail fundraising campaign. Petitioner received a total of about $<>2-1/4 million in net fundraising revenue under the Contract. W&H received more than $<>4 million in fees…

1Opinion of the Court

UNITED CANCER COUNCIL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United Cancer Council v. Commissioner

Tax Ct. Dkt. No. 2008-91X

United States Tax Court

109 T.C. 326; 1997 U.S. Tax Ct. LEXIS 70; 109 T.C. No. 17;

December 2, 1997, Filed

Decision will be entered for respondent.

Petitioner was organized in 1963. In a ruling letter dated Mar. 31, 1969, respondent ruled that petitioner was exempt from Federal income tax and was an eligible charitable donee. Secs. 501(a), 501(c)(3), 170(c), I.R.C. 1954.

On June 11, 1984, petitioner entered into a 5-year fundraising contract (the…

2Cases cited39 opinions

  1. Secretary of State of Md. v. Joseph H. Munson Co.Supreme Court of the United States · 1984
  2. Village of Schaumburg v. Citizens for a Better EnvironmentSupreme Court of the United States · 1980
  3. Riley v. National Federation of Blind of North Carolina, Inc.Supreme Court of the United States · 1988
  4. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  5. Bob Jones University v. United StatesSupreme Court of the United States · 1983

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