C. F. Mueller Co. v. Commissioner
United States Tax Court
Exempt -- Section 101 (6) -- Corporation Operating Regular Business. -- Congress, in section 101 (6), did not intend to include in the exempt class, as a corporation organized and operated exclusively for educational purposes, a corporation not engaged in educational work, but having as its only activity the operation of a regular competitive commercial business for profit, even though its earnings inure solely to the benefit of a separate corporation, a university, falling…
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Exempt -- Section 101 (6) -- Corporation Operating Regular Business. -- Congress, in section 101 (6), did not intend to include in the exempt class, as a corporation organized and operated exclusively for educational purposes, a corporation not engaged in educational work, but having as its only activity the operation of a regular competitive commercial business for profit, even though its earnings inure solely to the benefit of a separate corporation, a university, falling within the exempt class.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $136,438.62 in the income tax of the petitioner for the period beginning August 28 and ending December 31,1947. The sole issue for decision is whether the petitioner is exempt from tax under section 101 (6) of the Internal Revenue Code. The case was submitted upon a stipulation of facts, which is hereby adopted in its entirety as the findings of fact. Some of those facts are mentioned herein, but all have been carefully considered.
The petitioner was incorporated under the laws of Delaware on August 21, 1947. Its return for the…
2Cases cited4 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Osaka Shosen Kaisha Line v. United StatesSupreme Court of the United States · 1937
- Chattanooga Auto. Club v. CommissionerUnited States Tax Court · 1949
3Cited by46 opinions
- C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
- Danz v. CommissionerUnited States Tax Court · 1952
- Ohio Furnace Co. v. CommissionerUnited States Tax Court · 1955
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
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