Association of The Bar v. Commissioner
United States Tax Court
Petitioner seeks a declaratory judgment from respondent's adverse final determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954. Respondent determined that petitioner is an "action" organization, as defined in sec. 1.501(c)(3)-1(c)(3)(iii), Income Tax Regs., because petitioner's practice of rating candidates for elective judicial offices constitutes participation or intervention in any political campaign on behalf of any candidate for…
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Petitioner seeks a declaratory judgment from respondent's adverse final determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954. Respondent determined that petitioner is an "action" organization, as defined in sec. 1.501(c)(3)-1(c)(3)(iii), Income Tax Regs., because petitioner's practice of rating candidates for elective judicial offices constitutes participation or intervention in any political campaign on behalf of any candidate for public office, within the meaning of sec. 501(c)(3). Held, the mere act of rating candidates for judicial office, without…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
Petitioner, the Association of the Bar of the City of New York, seeks a declaratory judgment pursuant to section 7428(a)1 that it is exempt from taxation under section 501(a) as an organization described in section 501(c)(3). The sole issue for decision is whether petitioner’s practice of rating judicial candidates for public office constitutes participation or intervention in political campaigns on behalf of such candidates, which is prohibited by-section 501(c)(3).2
This case was submitted for decision on the stipulated administrative record under Rule 122. The…
2Cases cited12 opinions
- Cammarano v. United StatesSupreme Court of the United States · 1959
- Church of Scientology of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Christian Echoes National Ministry, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1973
- Slee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
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3Cited by3 opinions
- The Association of the Bar of the City of New York v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1988
- Fulani v. BradyDistrict Court, S.D. New York · 1993
- Association of The Bar v. CommissionerUnited States Tax Court · 1987