Aid to Artisans, Inc. v. Commissioner
United States Tax Court
Petitioner was organized as a nonprofit Massachusetts corporation to promote, improve, and expand the handicraft output of disadvantaged artisans in developing societies of the world. Based upon the provisions of sec. 501(c)(3), I.R.C. 1954, petitioner filed an application for exemption from income taxation with the Internal Revenue Service.
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Petitioner was organized as a nonprofit Massachusetts corporation to promote, improve, and expand the handicraft output of disadvantaged artisans in developing societies of the world. Based upon the provisions of sec. 501(c)(3), I.R.C. 1954, petitioner filed an application for exemption from income taxation with the Internal Revenue Service. Respondent determined that petitioner was not entitled to such an exemption because petitioner was not operated exclusively for exempt purposes as required by sec. 501(c)(3), I.R.C. 1954. Thereafter petitioner filed a petition with this Court for a…
1Opinion of the Court
OPINION
Goffe, Judge:
Petitioner has instituted this action pursuant to section 7428, I.R.C. 1954,1 for a declaratory judgment that it qualifies as an organization described in section 501(c)(8) and is entitled to an exemption from income tax under section 501(a). The issue for our decision is whether petitioner is operated exclusively for exempt purposes within the meaning of section 501(c)(3).
Both parties agree that the jurisdictional requirements of section 7428 and Rule 210(c), Tax Court Rules of Practice and Procedure, have been met. Pursuant to Rule 217(b)(1), Tax Court Rules of Practice…
2Cases cited14 opinions
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- Church in Boston v. CommissionerUnited States Tax Court · 1978
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