Callaway Family Asso. v. Commissioner
United States Tax Court
Petitioner is a family association formed as a nonprofit corporation to study immigration to and migration within the United States by focusing upon its own family history and genealogy. The administrative record shows its activities included researching the genealogy of its members for the ultimate purpose of publishing a family history.
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Petitioner is a family association formed as a nonprofit corporation to study immigration to and migration within the United States by focusing upon its own family history and genealogy. The administrative record shows its activities included researching the genealogy of its members for the ultimate purpose of publishing a family history. Respondent denied petitioner's application for an exemption from taxation under secs. 501(c)(3) and 501(a), I.R.C. 1954. Held: Petitioner's family genealogical activities are not insubstantial, and are not in furtherance of an exempt purpose, but rather…
1Opinion of the Court
OPINION
Wilbur, Judge:
Respondent determined that petitioner did not qualify for exemption from Federal income tax under section 501(a) as an organization described in section 501(c)(3).1 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 operated exclusively for educational purposes within the meaning of section 501(c)(3).
This case was submitted for decision at an oral hearing held on October 12, 1978. The stipulated administrative record was…
2Cases cited2 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Baltimore Regional Joint Board Health & Welfare Fund v. CommissionerUnited States Tax Court · 1978
3Cited by28 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Basic Bible Church v. CommissionerUnited States Tax Court · 1980
- Western Catholic Church v. CommissionerUnited States Tax Court · 1979
- Dumaine Farms v. CommissionerUnited States Tax Court · 1980
- Goldsboro Art League, Inc. v. CommissionerUnited States Tax Court · 1980
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