Automobile Club of Michigan v. Commissioner
United States Tax Court
1. In 1945 the respondent held that the petitioner was not an exempt organization under the Internal Revenue Code or under prior revenue acts, revoked rulings of exemption made in 1934 and 1938 and required petitioner to file returns for 1943 and 1944. Held, that the portion of Regulations 103, section 19.101-1, and the corresponding portions of earlier regulations, providing that where an organization established its right to exemption it need not thereafter make a return…
Read the full summary
1. In 1945 the respondent held that the petitioner was not an exempt organization under the Internal Revenue Code or under prior revenue acts, revoked rulings of exemption made in 1934 and 1938 and required petitioner to file returns for 1943 and 1944. Held, that the portion of Regulations 103, section 19.101-1, and the corresponding portions of earlier regulations, providing that where an organization established its right to exemption it need not thereafter make a return of income unless it changed its character, did not operate to exempt petitioner from tax for 1943 and 1944. 2. Held, that…
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in the petitioner’s income and excess profits taxes as follows:
Deficiencies Income Excess Year tax profits tax
1943_$49,016.97 $128,953.72
1944_ 48,781.99 157,307.29
1945_ 42, 373. 66 -
1946_ 13, 645. 94 _
1947_ 7,365.87 _
The principal issues are the correctness of the respondent’s action (1) in determining that the years 1943 through 1947 the petitioner was not exempt from income and excess profits taxes, as a club organized and operated exclusively for pleasure, recreation, and other nonprofitable purposes, within the purview of section 101…
2Cases cited10 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Danz v. CommissionerUnited States Tax Court · 1952
- Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
- Chattanooga Automobile Club v. Commissioner of Internal Revenue. Warren Automobile Club, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
5 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Beacon Publishing Company, a Kansas Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Fruehauf Trailer Co. v. CommissionerUnited States Tax Court · 1964
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
34 more not listed; retrieve them via the Exa API.