Legal Opinion

Santa Barbara Club v. Commissioner

United States Tax Court

Decided May 23, 1977No. Docket No. 8544-74PublishedCited by 7 opinions

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

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
  3. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  4. United States v. Leslie Salt Co.Supreme Court of the United States · 1956
  5. McGlotten v. ConnallyDistrict Court, District of Columbia · 1972

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3Cited by7 opinions

  1. Pittsburgh Press Club v. United StatesCourt of Appeals for the Third Circuit · 1978
  2. Associated Master Barbers & Beauticians, Inc. v. CommissionerUnited States Tax Court · 1977
  3. Tucker v. CommissionerUnited States Tax Court · 1978
  4. Afro-American Purchasing Center, Inc. v. CommissionerUnited States Tax Court · 1978
  5. Associated Master Barbers & Beauticians, Inc. v. CommissionerUnited States Tax Court · 1977

2 more not listed; retrieve them via the Exa API.

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