International E22 Class Asso. v. Commissioner
United States Tax Court
P, a yachting association, provided design and measurement tools in connection with its enforcement of amateur racing competition. Held, such provision does not constitute "the provision of athletic facilities or equipment" within the meaning of sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Wilbur, Judge-.
Petitioner requested a determination by respondent of petitioner’s qualification as an exempt organization described in section 501(c)(3).1 No notice of determination has been issued in this matter by respondent. Petitioner therefore invokes the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The sole issue for our decision is whether petitioner’s use of a "master plug” and "measurement templates” in enforcing amateur racing constitutes the provision of athletic facilities or equipment contrary to the proscription of sections 501(c)(3)…
2Cases cited5 opinions
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
- West Side Tennis Club v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Pittsburgh Press Club v. United StatesCourt of Appeals for the Third Circuit · 1976
- Maryland Country Club, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 1976
3Cited by1 opinion
- International E22 Class Asso. v. CommissionerUnited States Tax Court · 1982