Legal Opinion

Calhoun Academy v. Commissioner

United States Tax Court

Decided March 1, 1990No. Docket No. 6595-88XPublished

P, a private school, sought a declaratory judgment that it is exempt from tax under sec. 501(c)(3) of the Code. P maintains that it has the racially nondiscriminatory policy toward students required by Bob Jones University v. United States, 461 U.S. 574 (1983). Held, P must satisfy its burden of proof by a preponderance of the evidence.

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P, a private school, sought a declaratory judgment that it is exempt from tax under sec. 501(c)(3) of the Code. P maintains that it has the racially nondiscriminatory policy toward students required by Bob Jones University v. United States, 461 U.S. 574 (1983). Held, P must satisfy its burden of proof by a preponderance of the evidence. Federation Pharmacy Services v. Commissioner, 72 T.C. 687, 691 (1979), affd. 625 F.2d 804 (8th Cir. 1980). Held, further, P has failed to show that it operates in good faith in accordance with a nondiscriminatory policy toward black students and thus P does…

1Opinion of the Court

Calhoun Academy, Petitioner v. Commissioner of Internal Revenue, Respondent

Calhoun Academy v. Commissioner

Docket No. 6595-88X

United States Tax Court

94 T.C. 284; 1990 U.S. Tax Ct. LEXIS 15; 94 T.C. No. 17;

March 1, 1990March 1, 1990, Filed

Decision will be entered for the respondent.

P, a private school, sought a declaratory judgment that it is exempt from tax under sec. 501(c)(3) of the Code. P maintains that it has the racially nondiscriminatory policy toward students required by Bob Jones University v. United States, 461 U.S. 574 (1983). Held, P must satisfy its burden of proof by a…

2Cases cited13 opinions

  1. Runyon v. McCrarySupreme Court of the United States · 1976
  2. Bob Jones University v. United StatesSupreme Court of the United States · 1983
  3. United States v. CalderonSupreme Court of the United States · 1954
  4. Green v. ConnallyDistrict Court, District of Columbia · 1971
  5. Federation Pharmacy Services, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1980

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