United Cancer Council v. Commissioner
United States Tax Court
Petitioner was organized in 1963. In a ruling letter dated Mar. 31, 1969, respondent ruled that petitioner was exempt from Federal income tax and was an eligible charitable donee. Secs. 501(a), 501(c)(3), 170(c), I.R.C. 1954. On June 11, 1984, petitioner entered into a 5-year fundraising contract (the Contract) with a professional fundraiser (W&H). During 1984 through 1989, W&H helped petitioner conduct a nationwide direct mail fundraising campaign.
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Petitioner was organized in 1963. In a ruling letter dated Mar. 31, 1969, respondent ruled that petitioner was exempt from Federal income tax and was an eligible charitable donee. Secs. 501(a), 501(c)(3), 170(c), I.R.C. 1954. On June 11, 1984, petitioner entered into a 5-year fundraising contract (the Contract) with a professional fundraiser (W&H). During 1984 through 1989, W&H helped petitioner conduct a nationwide direct mail fundraising campaign. Petitioner received a total of about $<>2-1/4 million in net fundraising revenue under the Contract. W&H received more than $<>4 million in fees…
1Opinion of the Court
CONTENTS
Page
Introduction and Statement of Issues. 327
Findings of Fact . 328
Background and Summary. 329
Direct Mail Fundraising . 334
W&H; AICR. 339
The Contract; Related Agreements . 342
A. The Contract (June 11, 1984) . 342
B. The Escrow Agreement . 345
C. Petitioner’s “Draw” Arrangement . 347
D. Agreement To Continue at 50 Percent the Percentage of Net
Housefile Mailing Income the Fundraising Contract Required To Be Retained in the Escrow Account To Reimburse W&H. 349
E. April 1987 Addendum to the Contract . 350
Direct Mail Fundraising Campaign: 1984-89 . 352
A. In General. 352
B. W&H’s Advances of the…
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- Bob Jones University v. United StatesSupreme Court of the United States · 1983
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3Cited by2 opinions
- United Cancer Council v. CommissionerUnited States Tax Court · 1997
- United Cancer Council, Inc. v. CommissionerUnited States Tax Court · 1997