Legal Opinion

Gemological Institute of America v. Commissioner

United States Tax Court

Decided March 27, 1952No. Docket No. 26183Published

Petitioner corporation, which included in its activities the giving of instructive courses in gemmology, held, not exempt from tax under section 101 (6), I. R. C., because part of its net earnings inured to the benefit of an individual.

1Opinion of the Court

Gemological Institute of America, Petitioner, v. Commissioner of Internal Revenue, Commissioner

Gemological Institute of America v. Commissioner

Docket No. 26183

United States Tax Court

17 T.C. 1604; 1952 U.S. Tax Ct. LEXIS 234;

March 27, 1952, Promulgated

Decision will be entered under Rule 50.

Petitioner corporation, which included in its activities the giving of instructive courses in gemmology, held, not exempt from tax under section 101 (6), I. R. C., because part of its net earnings inured to the benefit of an individual.

Austin H. Peck, Jr., Esq., and Henry C. Diehl, Esq., for the petitioner.

R.…

2Cases cited3 opinions

  1. Commissioner of Internal Revenue v. OrtonCourt of Appeals for the Sixth Circuit · 1949
  2. Edward Orton, Ceramic Foundation v. CommissionerUnited States Tax Court · 1947
  3. Gemological Institute of America v. CommissionerUnited States Tax Court · 1952

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