Copyright Clearance Center, Inc. v. Commissioner
United States Tax Court
P is a corporation organized to provide a service through which public and private libraries, commercial organizations, and others may centrally pay license fees for copying of certain copyrighted publications. P does not provide copies of documents, but rather operates as a clearinghouse for licensing of copying and as a conduit for the transfer of license fees to copyright holders.
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P is a corporation organized to provide a service through which public and private libraries, commercial organizations, and others may centrally pay license fees for copying of certain copyrighted publications. P does not provide copies of documents, but rather operates as a clearinghouse for licensing of copying and as a conduit for the transfer of license fees to copyright holders. P was organized by a publishers' trade association, and its initial expenses were financed primarily by contributions solicited from publishers in accordance with the expected financial benefit to each publisher…
1Opinion of the Court
OPINION
Raum, Judge'.
The Commissioner determined that petitioner does not qualify for exemption from income taxation as an organization described in section 501(c)(3), I.R.C. 1954, and petitioner has invoked the jurisdiction of this Court to obtain a declaratory judgment as to its exempt status.1 The question presented is whether petitioner is organized and operated exclusively for exempt purposes. The case was submitted on the basis of the stipulated administrative record, which is incorporated herein by reference. The factual representations in the administrative record are accepted as true.…
2Cases cited20 opinions
- 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
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Christian Manner International, Inc. v. CommissionerUnited States Tax Court · 1979
- Est of Hawaii v. CommissionerUnited States Tax Court · 1979
15 more not listed; retrieve them via the Exa API.
3Cited by65 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Living Faith, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
- National Asso. of American Churches v. CommissionerUnited States Tax Court · 1984
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
60 more not listed; retrieve them via the Exa API.