Manning Ass'n v. Commissioner
United States Tax Court
Held: Manning Association, Inc., is not exempt from tax under sec. 501(c)(3) of the Code as an organization operated "exclusively for * * * educational purposes." Notwithstanding the existence of truly educational purposes based largely upon a historic Manning homestead and historic artifacts, the association's operations were also conducted for the benefit of members of the Manning family, a nonexempt purpose that is found to be "substantial in nature."
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Held: Manning Association, Inc., is not exempt from tax under sec. 501(c)(3) of the Code as an organization operated "exclusively for * * * educational purposes." Notwithstanding the existence of truly educational purposes based largely upon a historic Manning homestead and historic artifacts, the association's operations were also conducted for the benefit of members of the Manning family, a nonexempt purpose that is found to be "substantial in nature." Better Business Bureau v. United States, 326 U.S. 279, 283 (1945). There is no 10-percent "safe harbor" of nonexempt activities within which…
1Opinion of the Court
OPINION
RAUM, Judge:
The Commissioner determined that petitioner does not qualify for exemption from income taxation under section 501(c)(3).1 This case is before us on a petition for a declaratory judgment and a stipulation of the parties as to the correctness and completeness of the administrative record pursuant to Rule 217. The jurisdictional requirements specified in section 7428 have all been satisfied. At issue is whether petitioner is “operated exclusively for * * * educational purposes” under section 501(c)(3).
The evidentiary facts and representations contained in the administrative…
2Cases cited11 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982
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3Cited by18 opinions
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- Leila G. Newhall Unitrust v. CommissionerUnited States Tax Court · 1995
- Housing Pioneers v. CommissionerUnited States Tax Court · 1993
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