Legal Opinion

Chattanooga Auto. Club v. Commissioner

United States Tax Court

Decided June 8, 1949No. Docket No. 15138PublishedCited by 30 opinions

Exempt -- Section 101 (9) -- Automobile Club. -- An automobile club, rendering services to its members at less than they could be obtained elsewhere, which services are of the kind rendered by others for the profits to be earned thereby, is not exempt under section 101 (9), I. R. C.

1Opinion of the Court

OPINION.

Mukdock, Judge-.

The Commissioner has provided in his regulations for many years that an organization will not be deemed exempt if it engages in traffic for profit, Regulations 33, article 72, to Regulations 111, section 29.101 (9)-l, although a profit from an activity merely incidental to its primary purpose may not render it subject to tax. This petitioner has gone beyond its original purpose as set forth in its bylaws. It was not operated during the taxable year “exclusively for pleasure, recreation, and other nonprofitable purposes.” Sec. 101(9), I. R. C.1 Its principal activity…

2Cited by30 opinions

  1. C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1950
  2. Automobile Club of Michigan v. CommissionerUnited States Tax Court · 1953
  3. Keystone Automobile Club v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
  4. FEDERAL EMPLOYEES'DISTRIBUTING COMPANY v. United StatesDistrict Court, S.D. California · 1962
  5. Allied Trades Club, Inc. v. CommissionerUnited States Tax Court · 1955

25 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API