Piety, Inc. v. Commissioner
United States Tax Court
Petitioner seeks a declaratory judgment that it is exempt from taxation under sec. 501(c)(3), I.R.C. 1954. Petitioner's sole activity is the operation of bingo games. It intends to contribute its profits to exempt organizations. Held, petitioner may not qualify for exemption on the ground that it will donate its profits to exempt organizations.
1Opinion of the Court
OPINION
Clapp, Judge:
Respondent determined petitioner is not exempt from taxation under section 501(c)(3). Pursuant to section 7428,1 petitioner, having exhausted its administrative remedies, challenges that determination and seeks a declaration by this Court with respect to its initial qualification under section 501(c)(3).
This case was submitted under Tax Court Rule 122. The stipulated administrative record is incorporated herein by this reference. At the time its petition was filed, petitioner had its principal office in Nebraska.
Petitioner was organized under the laws of Nebraska on…
2Cases cited3 opinions
- Smith-Dodd Businessman's Asso. v. CommissionerUnited States Tax Court · 1975
- Industrial Aid for the Blind v. CommissionerUnited States Tax Court · 1979
- P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
3Cited by4 opinions
- P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
- P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
- Piety, Inc. v. CommissionerUnited States Tax Court · 1984
- Zagfly, Inc. v. Comm'rUnited States Tax Court · 2013