Legal Opinion
Phi Delta Theta Fraternity v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 3, 1990No. 88-1863PublishedCited by 18 opinions
1Opinion of the Court
ENGEL, Senior Circuit Judge.
In this appeal from the United States Tax Court, 90 T.C. 1033 (1988), we consider whether income derived from a special endowment and used by a college fraternity to pay for publication of its quarterly periodical is “exempt function income” under 26 U.S.C. § 512(a)(3)(B), and thus not taxable as “unrelated business taxable income” under 26 U.S.C. §§ 512-513.
The Phi Delta Theta Fraternity (“fraternity”) is a national college fraternity exempt from federal income taxation under 26 U.S.C. §§ 501(a) and 501(c)(7).1 The fraternity’s quarterly periodical, The Scroll,…
2Cases cited4 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Phi Delta Theta Fraternity v. CommissionerUnited States Tax Court · 1988
- Hutchinson Baseball Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1982
3Cited by18 opinions
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- Manning Ass'n v. CommissionerUnited States Tax Court · 1989
- Richie v. American Council on Gift AnnuitiesDistrict Court, N.D. Texas · 1996
- Comerica Bank, N.A., of the Estate of Russell v. Dancey v. United StatesCourt of Appeals for the Sixth Circuit · 1996
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