Est of Hawaii v. Commissioner
United States Tax Court
Petitioner engaged in activities relating to "est" programs involving training, seminars, lectures, etc., in areas of intrapersonal awareness and communication. Such activities were conducted under licensing arrangements with for-profit corporations.
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Petitioner engaged in activities relating to "est" programs involving training, seminars, lectures, etc., in areas of intrapersonal awareness and communication. Such activities were conducted under licensing arrangements with for-profit corporations. Held, in an action for a declaratory judgment under sec. 7428(a), I.R.C. 1954, petitioner's activities, although educational in nature, served the commercial purposes of the for-profit corporations and petitioner was therefore not operated exclusively for exempt purposes within the meaning of sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined that petitioner is not entitled to exemption from Federal income tax as an organization described in section 501(c)(3).1 Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The issue is whether petitioner is operated exclusively for one or more exempt purposes within the meaning of section 501(c)(3). This case is before us on petitioner’s and respondent’s motions for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Peti…
2Cases cited22 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
17 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982
- Federation Pharmacy Services, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1980
- People of God Community v. CommissionerUnited States Tax Court · 1980
- Federation Pharmacy Services, Inc. v. CommissionerUnited States Tax Court · 1979
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