Legal Opinion

Interneighborhood Housing Corp. v. Commissioner

United States Tax Court

Decided November 16, 1982No. Docket No. 20885-81XUnpublished

P, a nonprofit corporation, received fees from the City of New York for managing eight apartment buildings owned by the city as a result of tax foreclosures. Held, P has failed to prove that it is organized and operated exclusively for charitable purposes under sec. 501(c)(3), I.R.C. 1954.

1Opinion of the Court

INTERNEIGHBORHOOD HOUSING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Interneighborhood Housing Corp. v. Commissioner

Docket No. 20885-81X.

United States Tax Court

T.C. Memo 1982-661; 1982 Tax Ct. Memo LEXIS 86; 45 T.C.M. (CCH) 115; T.C.M. (RIA) 82661;

November 16, 1982.

P, a nonprofit corporation, received fees from the City of New York for managing eight apartment buildings owned by the city as a result of tax foreclosures. Held, P has failed to prove that it is organized and operated exclusively for charitable purposes under sec. 501(c)(3), I.R.C. 1954.

Msgr. John C.…

2Cases cited27 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  3. Davis v. CommissionerUnited States Tax Court · 1976
  4. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  5. Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977

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