Christian Stewardship Assistance, Inc. v. Commissioner
United States Tax Court
Petitioner was formed as a nonprofit corporation to assist charitable organizations in their fundraising activities with individual contributors. Petitioner engaged in a service which provided financial planning advice on charitable giving and tax planning to wealthy individuals referred to it by subscribing charitable organizations.
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Petitioner was formed as a nonprofit corporation to assist charitable organizations in their fundraising activities with individual contributors. Petitioner engaged in a service which provided financial planning advice on charitable giving and tax planning to wealthy individuals referred to it by subscribing charitable organizations. Held: In an action brought under sec. 7428(a), I.R.C. 1954, for declaratory judgment on petitioner's qualifications as an exempt organization under sec. 501(a) and (c)( 3), I.R.C. 1954, petitioner's tax planning services are a nonexempt activity that is…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(a)1 as an organization described in section 501(c)(3). Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The issue for our decision is whether petitioner is engaged primarily in activities which accomplish exempt purposes within the meaning of section 501(c)(3).
This case is submitted under Rule 122, Tax Court Rules of Practice and Procedure. The joint stipulation…
2Cases cited8 opinions
- Chevron Oil Co. v. HusonSupreme Court of the United States · 1971
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Pulpit Resource v. CommissionerUnited States Tax Court · 1978
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3Cited by42 opinions
- Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982
- Christian Manner International, Inc. v. CommissionerUnited States Tax Court · 1979
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Est of Hawaii v. CommissionerUnited States Tax Court · 1979
- Dumaine Farms v. CommissionerUnited States Tax Court · 1980
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