St. Joseph Farms of Indiana Bros. of Congregation of Holy Cross, Southwest Province, Inc. v. Commissioner
United States Tax Court
Petitioner, an Indiana not-for-profit corporation, is exempt from tax as a member of the U.S. Catholic Conference, which has been granted a group exemption under sec. 501(c)(3), I.R.C. 1954. Petitioner is part of the Congregation of the Holy Cross, an apostolic religious order. Prior to 1955, the Holy Cross Brothers had but one province in the United States.
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Petitioner, an Indiana not-for-profit corporation, is exempt from tax as a member of the U.S. Catholic Conference, which has been granted a group exemption under sec. 501(c)(3), I.R.C. 1954. Petitioner is part of the Congregation of the Holy Cross, an apostolic religious order. Prior to 1955, the Holy Cross Brothers had but one province in the United States. In 1955, that province was divided into three separate provinces (Southwest, Midwest, and Eastern), and petitioner was given to the Southwest Province to provide that province with a source of income. Petitioner operates a 1600 acre farm…
1Opinion of the Court
Jacobs, Judge:
Respondent determined the following deficiencies in petitioner’s income tax:
TYE June 30— Deficiency
1977. $857
1978 . 7,522
1979. 18,836
The issues for decision are: (1) Whether the farming operations conducted by petitioner (an organization exempt from income tax pursuant to section 501 1) during the years 1977, 1978, and 1979 constitute the conduct of an unrelated trade or business within the meaning of section 513, and (2) if the farming operations constitute an unrelated trade or business, whether substantially all of the work in carrying on the trade or business was performed…
2Cases cited7 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
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