Suffolk County Patrolmen's Benevolent Asso. v. Commissioner
United States Tax Court
Petitioner is an exempt organization under sec. 501(c)(4), I.R.C. 1954. During each of the years 1974, 1975, and 1976, it conducted an annual fundraising activity consisting of the presentation and sponsoring of a professional vaudeville show. In conjunction with said shows, petitioner published program guides containing paid advertising as well as editorial matter.
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Petitioner is an exempt organization under sec. 501(c)(4), I.R.C. 1954. During each of the years 1974, 1975, and 1976, it conducted an annual fundraising activity consisting of the presentation and sponsoring of a professional vaudeville show. In conjunction with said shows, petitioner published program guides containing paid advertising as well as editorial matter. Held, under sec. 1.513-1(c)(2), Income Tax Regs., the annual vaudeville shows (and accompanying program guides) were intermittent activities which did not constitute an unrelated trade or business which was "regularly carried on,"…
1Opinion of the Court
Forrester, Judge:
In these consolidated cases, respondent has determined deficiencies in petitioner’s Federal income taxes as follows:
Year Docket No. Deficiency
1974 . 6171-79 $54,069
1975 . 6171-79 28,285
1976 .10250-80 48,605
The sole issue for decision is whether petitioner’s fundraising activities during the taxable years 1974,1975, and 1976, which consisted of the presentation and sponsoring of professional entertainment shows and the sale of advertising in a program guide, constituted an unrelated trade or business which was regularly carried on, the income from which is taxable as unrelated…
2Cases cited3 opinions
- Smith-Dodd Businessman's Asso. v. CommissionerUnited States Tax Court · 1975
- The Hope School v. United StatesCourt of Appeals for the Seventh Circuit · 1980
- Edwards v. CommissionerUnited States Tax Court · 1959
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- Veterans of Foreign Wars, Dep't of Michigan v. CommissionerUnited States Tax Court · 1987
- Ye Mystic Krewe of Gasparilla v. CommissionerUnited States Tax Court · 1983
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