North Ridge Country Club v. Commissioner
United States Tax Court
Petitioner, a private social club exempt from tax pursuant to sec. 501(c)(7), I.R.C. 1954, engaged in three nonexempt activities: nonmember banquets, nonmember golf tournaments with associated banquets, and an investment program. Held, each nonexempt activity, separately considered, was entered into by petitioner with a profit objective. Held, further, losses from one such profit-seeking activity are deductible against net gains from another such activity.
1Opinion of the Court
OPINION
Korner, Judge:
This case was assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section 7456(d)(3) of the Code (redesignated sec. 7443A(b)(3) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181, and 182.1 The Court agrees with and adopts her opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
BUCKLEY, Special Trial Judge:
Respondent determined a deficiency of $2,846 in petitioner’s 1979 Federal income tax. The issue before the Court is whether petitioner, a section 501(c)(7) tax-exempt social club with…
2Cases cited9 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- United States v. Public Utilities CommissionSupreme Court of the United States · 1953
- Scott v. CommissionerUnited States Tax Court · 1985
- The Brook, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
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3Cited by16 opinions
- Portland Golf Club v. CommissionerSupreme Court of the United States · 1990
- Simon v. Comm'rUnited States Tax Court · 1994
- West Virginia State Medical Asso. v. CommissionerUnited States Tax Court · 1988
- Natomas North America, Inc. v. CommissionerUnited States Tax Court · 1988
- North Ridge Country Club v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
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