Retired Teachers Legal Defense Fund, Inc. v. Commissioner
United States Tax Court
Petitioner is organized to protect the financial stability of the New York City Teachers' Retirement System and the contributions and pensions of retiree members of that system and is currently involved in litigation to serve these purposes. Held, denying tax-exempt status to petitioner does not violate petitioner's First Amendment rights. Held, further, various parts of sec. 1.501(c)(3)-1(d), Income Tax Regs., are constitutionally valid.
Read the full summary
Petitioner is organized to protect the financial stability of the New York City Teachers' Retirement System and the contributions and pensions of retiree members of that system and is currently involved in litigation to serve these purposes. Held, denying tax-exempt status to petitioner does not violate petitioner's First Amendment rights. Held, further, various parts of sec. 1.501(c)(3)-1(d), Income Tax Regs., are constitutionally valid. Held, further, sec. 1.501(c)-1(c)(1), Income Tax Regs., is not unconstitutionally vague. Held, further, petitioner is organized and operated to serve the…
1Opinion of the Court
OPINION
Tietjens, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner, challenging respondent’s adverse determination, has invoked the jurisdiction of this Court for a declaratory judgment2 pursuant to section 7428.
The issue for our decision is whether petitioner is organized and operated exclusively for one or more exempt purposes within the meaning of section 501(c)(3) or whether petitioner serves private rather than public interests.
The case was submitted for decision on a stipulated administrative record…
2Cases cited29 opinions
- Grayned v. City of RockfordSupreme Court of the United States · 1972
- Connally v. General Construction Co.Supreme Court of the United States · 1926
- National Ass'n for the Advancement of Colored People v. ButtonSupreme Court of the United States · 1963
- Smith v. GoguenSupreme Court of the United States · 1974
- Associated Press v. United StatesSupreme Court of the United States · 1945
24 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Trans City Life Ins. Co. v. CommissionerUnited States Tax Court · 1996
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
- Columbia Park & Recreation Asso. v. CommissionerUnited States Tax Court · 1987
- Phi Delta Theta Fraternity v. CommissionerUnited States Tax Court · 1988
17 more not listed; retrieve them via the Exa API.