Santa Barbara Club v. Commissioner
United States Tax Court
Petitioner, a corporation organized as a social club, sold bottled liquor to its members for consumption away from the club's premises. For each year in issue, such sales exceeded 25 percent of the club's total gross receipts. Held, petitioner was not operated exclusively for exempt purposes and did not qualify for tax exemption under sec. 501(c)(7), I.R.C. 1954.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Year Income tax
1969. $774
1970. 912
1971. 743
The sole issue for our consideration is whether a social club’s status as a tax-exempt organization under section 501(c)(7)1 can be revoked because the club sold liquor to its members for consumption away from the club’s premises.
FINDINGS OF FACT
Some of the facts are stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by reference.
The Santa Barbara Club (hereinafter petitioner or the club) is…
2Cases cited19 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- United States v. Leslie Salt Co.Supreme Court of the United States · 1956
- McGlotten v. ConnallyDistrict Court, District of Columbia · 1972
14 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Pittsburgh Press Club v. United StatesCourt of Appeals for the Third Circuit · 1978
- Associated Master Barbers & Beauticians, Inc. v. CommissionerUnited States Tax Court · 1977
- Tucker v. CommissionerUnited States Tax Court · 1978
- Afro-American Purchasing Center, Inc. v. CommissionerUnited States Tax Court · 1978
- Associated Master Barbers & Beauticians, Inc. v. CommissionerUnited States Tax Court · 1977
2 more not listed; retrieve them via the Exa API.