Legal Opinion
Orange County Agricultural Society, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 19, 1990No. 587, Docket 88-4161PublishedCited by 16 opinions
1Opinion of the Court
SAND, District Judge:
Orange County Agricultural Society, Inc. (“Society” or “Taxpayer”) commenced this action in the United States Tax Court pursuant to section 7428(a) of the Internal Revenue Code1 seeking a declaratory judgment that, contrary to the determination of the Commissioner of Internal Revenue, it remained qualified as a tax-exempt organization under section 501(c)(3). After trial, the Tax Court, Julian I. Jacobs, J., sustained the Commissioner’s determination and held that Taxpayer is no longer so qualified. We affirm.
BACKGROUND
Taxpayer was incorporated in the State of New York in…
2Cases cited12 opinions
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Church of Scientology of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
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3Cited by16 opinions
- Steven Hoffenberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
- Southeast Rural Volunteer Fire Department v. Nebraska Department of RevenueNebraska Supreme Court · 1997
- Family Trust of Massachusetts, Inc. v. United StatesDistrict Court, District of Columbia · 2012
- Fund for the Study of Economic Growth & Tax Reform v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1998
- Airlie Foundation, Inc. v. United StatesDistrict Court, District of Columbia · 1993
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