Rameses Sch. v. Comm'r
United States Tax Court
P was established as a nonprofit corporation under the laws of the State of Texas for the purpose of operating a school providing education to children in the San Antonio area. P initially received recognition from R as an organization described in sec. 501(c)(3), I.R.C., which recognition R now seeks to revoke. Held: P furthers private interests and therefore is not operated exclusively for exempt charitable and/or educational purposes.
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P was established as a nonprofit corporation under the laws of the State of Texas for the purpose of operating a school providing education to children in the San Antonio area. P initially received recognition from R as an organization described in sec. 501(c)(3), I.R.C., which recognition R now seeks to revoke. Held: P furthers private interests and therefore is not operated exclusively for exempt charitable and/or educational purposes. Consequently, P is not entitled to exemption from income taxation under sec. 501(a), I.R.C., as an organization described in sec. 501(c)(3), I.R.C.
1Opinion of the Court
RAMESES SCHOOL OF SAN ANTONIO, TEXAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rameses Sch. v. Comm'r
No. 23228-04X
United States Tax Court
T.C. Memo 2007-85; 2007 Tax Ct. Memo LEXIS 83; 93 T.C.M. (CCH) 1092;
April 10, 2007, Filed
P was established as a nonprofit corporation under the laws of
the State of Texas for the purpose of operating a school providing education to children in the San Antonio area. P initially received recognition from R as an organization described in sec. 501(c)(3), I.R.C., which recognition R now
seeks to revoke.
Held: P furthers private interests and…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
- Unitary Mission Church v. CommissionerUnited States Tax Court · 1980
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