P.L.L. Scholarship Fund v. Commissioner
United States Tax Court
Petitioner was incorporated as a nonprofit corporation under Iowa statutes for the purpose of raising money to be used for providing college scholarships. The money was raised from the operation of bingo games on the premises of the Pastime Lounge. Held: Petitioner was not operated exclusively for exempt purposes under the provisions of sec. 501(c)(3), I.R.C. 1954, and sec. 1.501(c)(3)-1(c)(1), Income Tax Regs. Therefore, it is not exempt from Federal income tax.
1Opinion of the Court
OPINION
Pate, Special Trial Judge:
The petitioner has, pursuant to section 7428,1 invoked the jurisdiction of this Court to determine whether it is exempt from Federal income tax under section 501(c)(3). The statutory requirements for this Court’s declaratory judgment jurisdiction have been satisfied. The question presented is whether the petitioner is operated exclusively for charitable purposes within the meaning of section 501(c)(3).
This case was submitted on a stipulated administrative record under Rules 122 and 217, Tax Court Rules of Practice and Procedure. The stipulated record, which is…
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