People's Educational Camp Soc. v. Commissioner
United States Tax Court
The petitioner corporation which was organized in 1920 under the Membership Corporation Law of New York, operated during the taxable year 1956 the largest and one of the most modern vacation resorts in the Commonwealth of Pennsylvania. It charged its guests substantial rates for the accommodations and activities there provided.
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The petitioner corporation which was organized in 1920 under the Membership Corporation Law of New York, operated during the taxable year 1956 the largest and one of the most modern vacation resorts in the Commonwealth of Pennsylvania. It charged its guests substantial rates for the accommodations and activities there provided. Its total revenues for the taxable year, derived principally from the operation of the resort, were more than $ 940,000; and only a relatively small portion of the same was used for the promotion of social welfare. It had net assets, represented principally by…
1Opinion of the Court
PieRoe, Judge:
Respondent determined a deficiency of $25,784.43 in the income tax of the above-named petitioner corporation for its fiscal year ended September 30,1956.
The sole issue for decision is whether, for said taxable year, the petitioner corporation is entitled to exemption from Federal income tax under section 501(c) (4) of the 1954 Code. This section, in material part, provides exemption for:(4) Civic leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare * * *.
FINDINGS OF FACT.
Some of the facts have been stipulated. The written…
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