Legal Opinion

Unity School of Christianity v. Commissioner

United States Board of Tax Appeals

Decided April 23, 1926No. Docket No. 1799PublishedCited by 5 opinions

A corporation otherwise exempt from tax is not deprived of exemption because it carries on profitable or competitive activities in furtherance of its predominant religious, charitable, scientific, or educational purpose.

1Opinion of the Court

*67OPINION.

Steeniiagen :

The petitioner claims to be exempt from income and profits taxes by virtue of the provisions of the revenue acts in effect- during the taxable years in question, which provide that .the following organizations shall be exempt from taxation thereunder :

Corporations organized and operated exclusively for, religious, charitable, scientific, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual. .

This is section 231 (6) of the Revenue Act of 1918,…

2Cases cited1 opinion

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924

3Cited by5 opinions

  1. C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
  2. United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
  3. Elisian Guild, Inc. v. United StatesDistrict Court, D. Massachusetts · 1968
  4. Hillcrest Country Club, Inc. v. United StatesDistrict Court, W.D. Missouri · 1957
  5. Living Faith, Inc. v. CommissionerUnited States Tax Court · 1990

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