Legal Opinion

University Hill Foundation v. Commissioner

United States Tax Court

Decided January 8, 1969No. Docket Nos. 73993, 5311-65, 1482-66Published

Petitioner was organized in 1945 as a nonprofit corporation under the laws of the State of California to raise funds for Loyola University of Los Angeles, and has been operated for that purpose up to the present time. It was ruled exempt from Federal income tax until 1956, when the exemption was revoked.

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Petitioner was organized in 1945 as a nonprofit corporation under the laws of the State of California to raise funds for Loyola University of Los Angeles, and has been operated for that purpose up to the present time. It was ruled exempt from Federal income tax until 1956, when the exemption was revoked. Over the 1947-54 period, petitioner purchased a number of going businesses and leased the assets to newly formed operating companies in which the former owners acquired minority interests. Held, petitioner was not a "feeder organization" as defined in sec. 502, I.R.C. 1954. Held, further,…

1Opinion of the Court

University Hill Foundation, Formerly Loyola University Foundation, Petitioner v. Commissioner of Internal Revenue, Respondent

University Hill Foundation v. Commissioner

Docket Nos. 73993, 5311-65, 1482-66

United States Tax Court

51 T.C. 548; 1969 U.S. Tax Ct. LEXIS 213;

January 8, 1969, Filed

Decisions will be entered under Rule 50.

Petitioner was organized in 1945 as a nonprofit corporation under the laws of the State of California to raise funds for Loyola University of Los Angeles, and has been operated for that purpose up to the present time. It was ruled exempt from Federal income tax until…

Also in this document: Dissent · Raum; Dissent · Sterrett.

2Cases cited36 opinions

  1. Flora v. United StatesSupreme Court of the United States · 1960
  2. Commissioner v. BrownSupreme Court of the United States · 1965
  3. Flora v. United StatesSupreme Court of the United States · 1958
  4. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  5. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924

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