Ohio County and Independent Agriculture Societies, Delaware County Fair v. Commissioner of Internal Revenue

ORDER

Appellant, Ohio County and Independent Agriculture Societies, Delaware County Fair, was determined by the Commissioner of Internal Revenue in 1960 to be entitled to tax treatment under § 501(c)(3) of the Internal Revenue Code which meant that it was exempt from federal income tax as an educational organization and that contributions to it are deductible under § 170(c)(2). However, as such an organization it is subject to such tax with respect to its “unrelated business income” pursuant to §§ 511 through 515 of the Code. Contending that it is entitled to more favorable tax treatment under…