Associated Master Barbers & Beauticians, Inc. v. Commissioner
United States Tax Court
Held: 1. During the years in issue petitioner did not qualify as a tax-exempt trade association or business league within the provisions of sec. 501(c)(6), I.R.C. 1954, and sec. 1.501(c)(6)-1, Income Tax Regs. It engaged in a regular business of a kind ordinarily carried on for profit and its activities were directed to the performance of particular services for individual members.
Read the full summary
Held: 1. During the years in issue petitioner did not qualify as a tax-exempt trade association or business league within the provisions of sec. 501(c)(6), I.R.C. 1954, and sec. 1.501(c)(6)-1, Income Tax Regs. It engaged in a regular business of a kind ordinarily carried on for profit and its activities were directed to the performance of particular services for individual members. Therefore, respondent properly revoked petitioner's tax-exempt status for such years. 2. Petitioner is a membership organization operated primarily to furnish services or goods to its members and it therefore…
1Opinion of the Court
Dawson, Judge:
In these consolidated cases respondent determined the following deficiencies in petitioner’s Federal income taxes:
TYE Sept. 30— Deficiency
1967. . $7,789.25
1970. .591.96
TYE Sept. 30— Deficiency '
1971. ...3,697.60
1973. ...5,067.00
The issues presented for decision are (1) whether the petitioner qualified as an organization exempt from taxation under section 501(c)(6)1 during the years in question and (2) if the petitioner was not exempt from taxation, whether it was a membership organization within the meaning of section 277, so as to prevent the carryback of its net operating loss…
2Cases cited11 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Key Buick Co. v. CommissionerUnited States Tax Court · 1977
- Associated Industries v. CommissionerUnited States Tax Court · 1946
- Northwestern Municipal Ass'n v. United StatesCourt of Appeals for the Eighth Circuit · 1938
- Sun-Herald Corporation v. DugganCourt of Appeals for the Second Circuit · 1934
6 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Concord Consumers Hous. Coop. v. CommissionerUnited States Tax Court · 1987
- Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
- Carolinas Farm & Power Equipment Dealers Association, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1983
- Estate of Bowers v. CommissionerUnited States Tax Court · 1990
- Farm Service Cooperative v. CommissionerUnited States Tax Court · 1978
25 more not listed; retrieve them via the Exa API.