Paratransit Ins. Corp. v. Commissioner
United States Tax Court
P is a California nonprofit mutual benefit insurance corporation. It provides automobile liability insurance to its members, all of which are tax-exempt social service organizations that furnish transportation to the elderly, the handicapped, the needy, etc.
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P is a California nonprofit mutual benefit insurance corporation. It provides automobile liability insurance to its members, all of which are tax-exempt social service organizations that furnish transportation to the elderly, the handicapped, the needy, etc. The premiums paid by a member for such insurance are determined actuarially to take into account a number of factors, such as the deductibles selected by the member, the number of vehicles used by the member, the number of passengers carried by each vehicle, and the radius of the member's operations. 1. Held, P is not exempt under sec.…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined that petitioner is not an organization described in section 501(c)(3)1 and that it is not exempt from Federal income tax under section 501(a) for the taxable year 1988 and subsequent years. Petitioner has invoked the jurisdiction of this Court pursuant to section 7428 to obtain a declaratory judgment as to whether it meets the requirements of section 501(c)(3) and therefore qualifies- for tax-exempt status under section 501(a). The case was submitted on the basis of a stipulated administrative record.
At the time of filing its petition,…
2Cases cited5 opinions
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- Murray Seasongood and Agnes Seasongood v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Haswell v. United StatesUnited States Court of Claims · 1974
- Mutual Aid Association of the Church of the Brethren v. United StatesCourt of Appeals for the Tenth Circuit · 1985
- American Ass'n of Christian Schools Voluntary Employees Beneficiary Ass'n Welfare Plan Trust v. United StatesDistrict Court, M.D. Alabama · 1987
3Cited by5 opinions
- Florida Hosp. Trust Fund v. CommissionerUnited States Tax Court · 1994
- Nonprofits' Insurance Alliance of California v. United StatesUnited States Court of Federal Claims · 1994
- Florida Hosp. Trust Fund v. CommissionerUnited States Tax Court · 1994
- Florida Independent Colleges and Universities Risk Management Association, Inc. v. Internal Revenue ServiceDistrict Court, District of Columbia · 2012
- Paratransit Ins. Corp. v. CommissionerUnited States Tax Court · 1994