Legal Opinion

Columbia Park & Recreation Asso. v. Commissioner

United States Tax Court

Decided January 6, 1987No. Docket No. 19537-84XPublishedCited by 22 opinions

P is a sec. 501(c)(4), I.R.C. 1954, organization exempt from tax under sec. 501(a), I.R.C. 1954. P sought to be qualified as a charitable organization under sec. 501(c)(3), I.R.C. 1954, to, among other things, be able to obtain the benefit of sec. 103, I.R.C. 1954, bond financing.

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P is a sec. 501(c)(4), I.R.C. 1954, organization exempt from tax under sec. 501(a), I.R.C. 1954. P sought to be qualified as a charitable organization under sec. 501(c)(3), I.R.C. 1954, to, among other things, be able to obtain the benefit of sec. 103, I.R.C. 1954, bond financing. R issued an adverse ruling determining that P was not organized or operated exclusively for an exempt purpose within the meaning of sec. 501(c)(3), I.R.C. 1954. P seeks a declaratory judgment from R's adverse ruling. C is a private real estate development with a population of more than 100,000 residents. It is a…

1Opinion of the Court

GERBER, Judge:

This is an action for declaratory judgment pursuant to section 7428.1

By a final adverse ruling dated March 21, 1984, respondent determined that petitioner is neither organized nor operated exclusively for exempt purposes within the meaning of section 501(c)(3). Petitioner invokes the jurisdiction of this Court and challenges respondent’s adverse determination,2 seeking a declaratory judgment.3

The issue for our consideration is whether petitioner, a section 501(c)(4) organization, qualifies as a section 501(c)(3) charitable organization. This case was submitted fully stipulated…

2Cases cited35 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Burnet v. HarmelSupreme Court of the United States · 1932
  3. Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
  4. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  5. New York v. MacLaySupreme Court of the United States · 1933

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3Cited by22 opinions

  1. American Campaign Academy v. CommissionerUnited States Tax Court · 1989
  2. Nationalist Movement v. CommissionerUnited States Tax Court · 1994
  3. Partners in Charity, Inc. v. CommissionerUnited States Tax Court · 2013
  4. Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000
  5. Public Industries, Inc. v. CommissionerUnited States Tax Court · 1991

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