Legal Opinion

Hutchinson Baseball Enterprises, Inc. v. Commissioner

United States Tax Court

Decided October 24, 1979No. Docket No. 13326-78XPublished

Petitioner's advance ruling that it was exempt within meaning of sec. 501(c)(3), I.R.C. 1954, revoked on grounds that it was "not organized and operated for a charitable purpose." Petitioner's articles of incorporation provided that its purpose was to promote, advance, and sponsor baseball, including little league and amateur baseball, in designated area. Its main activity was funding and operating a baseball team, the Hutchinson Broncos.

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Petitioner's advance ruling that it was exempt within meaning of sec. 501(c)(3), I.R.C. 1954, revoked on grounds that it was "not organized and operated for a charitable purpose." Petitioner's articles of incorporation provided that its purpose was to promote, advance, and sponsor baseball, including little league and amateur baseball, in designated area. Its main activity was funding and operating a baseball team, the Hutchinson Broncos. Held: Petitioner is entitled to sec. 501(c)(3) exemption. Purpose cited above qualifies as an exempt organizational purpose. Broncos was an amateur team…

1Opinion of the Court

Hutchinson Baseball Enterprises, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Hutchinson Baseball Enterprises, Inc. v. Commissioner

Docket No. 13326-78X

United States Tax Court

73 T.C. 144; 1979 U.S. Tax Ct. LEXIS 30;

October 24, 1979, Filed

Decision will be entered for the petitioner.

Petitioner's advance ruling that it was exempt within meaning of sec. 501(c)(3), I.R.C. 1954, revoked on grounds that it was "not organized and operated for a charitable purpose." Petitioner's articles of incorporation provided that its purpose was to promote, advance, and sponsor baseball,…

2Cases cited5 opinions

  1. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  2. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  3. Hutchinson Baseball Enterprises, Inc. v. CommissionerUnited States Tax Court · 1979
  4. Peters v. CommissionerUnited States Tax Court · 1953
  5. Mobile Arts and Sports Association v. United StatesDistrict Court, S.D. Alabama · 1957

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