Michigan Mobile Home & Recreational Vehicle Institute v. Commissioner
United States Tax Court
Petitioner, a nonprofit organization for the promotion of the mobile home industry, sponsored a trade show for the display of camper and travel trailer vehicles in 1971 and 1972. Exhibition space was rented to petitioner's members and nonmembers at like rates. Subsequent to each show, petitioner made substantial space rental rebates to its member-exhibitors.
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Petitioner, a nonprofit organization for the promotion of the mobile home industry, sponsored a trade show for the display of camper and travel trailer vehicles in 1971 and 1972. Exhibition space was rented to petitioner's members and nonmembers at like rates. Subsequent to each show, petitioner made substantial space rental rebates to its member-exhibitors. Held, that petitioner failed to qualify as a tax-exempt organization under sec. 501(c)(6) for 1971 and 1972 since a part of its net earnings inured to the benefit of member-exhibitors who received space rental rebates. Held, further, that…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
TYEJune30— Deficiency
1971_ $34,714.06
1972_ 33,224.85
The issues before us are: (1) Whether petitioner qualified as an organization exempt from taxation under section 501(c)(6)1 during the years in question and (2) if petitioner did not so qualify, whether that portion of petitioner’s net proceeds from the sponsorship of a trade show during each of the years in question which petitioner distributed to its members who exhibited at such show as exhibition space rent rebates was…
2Cases cited18 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Associated Industries v. CommissionerUnited States Tax Court · 1946
- Crooks v. Kansas City Hay Dealers' Ass'nCourt of Appeals for the Eighth Circuit · 1929
- Uniform Printing & Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1937
13 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Michigan Mobile Home & Recreational Vehicle Institute v. CommissionerUnited States Tax Court · 1976
- Mikel A. Brown, Sr. & Debra A. Brown v. CommissionerUnited States Tax Court · 2019