Grange Ins. Asso. v. Commissioner
United States Tax Court
Petitioner, organized and operated at cost to enable members of the California State Grange to contribute to each other's fire losses by means of premiums and assessments, held not qualified for exemption under section 501(c)(8) of the 1954 Code as paying "life, sick, accident or other benefits."
1Opinion of the Court
OPINION.
Opper, Judge:
Although petitioner did not itself operate “under the lodge system” within the meaning of section 501(c) (8) of the 1954 Code,1 it is clear that it conforms to the exemption provision of subsection (A) because it operates “for the exclusive benefit of the members of a fraternity [the Grange] itself operating under the lodge system.” This is, in effect, conceded by respondent. As will presently appear, we need not deal with his contention that petitioner was a “Mutual insurance compan [y] * * * other than life or marine”2 under section 501(c) (15) and, as such, could not…
2Cases cited7 opinions
- Commissioner of Internal Revenue v. TreganowanCourt of Appeals for the Second Circuit · 1950
- Estate of Strauss v. CommissionerUnited States Tax Court · 1949
- Estate of Edmonds v. CommissionerUnited States Tax Court · 1951
- Miller v. Maryland Casualty Co.Court of Appeals for the Third Circuit · 1912
- Philadelphia & Reading Relief Asso. v. CommissionerUnited States Board of Tax Appeals · 1926
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- The Grange Insurance Association of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Grange Ins. Asso. v. CommissionerUnited States Tax Court · 1961