Lorain Ave. Clinic v. Commissioner
United States Tax Court
Held, petitioner was not organized and operated exclusively for charitable purposes and, therefore, it is not exempt from income taxes for the years 1945-1953, inclusive. Sec. 101 (6), I. R. C. 1939.
1Opinion of the Court
OPINION.
Harron, Judge:
Whether or not petitioner is a corporation the income of which is taxable for each of the years 1945-1953, inclusive, depends on (1) whether petitioner qualified for exemption from tax during that 9-year period under the provisions of section 101 (6), 1939 Code,1 and (2) whether respondent abused his discretion under section 3791 (b)2 in retroactively holding petitioner taxable for the 9-year period upon his revocation on January 22,1953, of his ruling of July 21,1941, under which he held that petitioner was entitled to exemption from tax under section 101 (6).
In order…
2Cases cited10 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- The Lesavoy Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
- Automobile Club of Michigan v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
5 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Federation Pharmacy Services, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1980
- Lorain Ave. Clinic v. CommissionerUnited States Tax Court · 1958