Goldsboro Art League, Inc. v. Commissioner
United States Tax Court
Besides its many undisputedly educational and charitable activities, petitioner operates two art galleries which exhibit and sell artworks. In order to insure artistic quality and integrity, the artworks displayed are selected by jury procedures and often represent the artist's more daring works.
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Besides its many undisputedly educational and charitable activities, petitioner operates two art galleries which exhibit and sell artworks. In order to insure artistic quality and integrity, the artworks displayed are selected by jury procedures and often represent the artist's more daring works. None of the artists whose works have been exhibited is on petitioner's board of directors or is an officer of petitioner; however, 2 of the over 100 artists who have had their work displayed are members of petitioner. Approximately 80 percent of the sales proceeds are paid to the artists; petitioner…
1Opinion of the Court
OPINION
Tietjens, Judge:
Respondent determined that petitioner is not exempt from Federal income tax under section 501(c)(3).1 The prerequisites for declaratory judgment having been satisfied,2 petitioner has, pursuant to section 7428, invoked the jurisdiction of this Court.
The issue3 for our determination is whether petitioner is operated exclusively for one or more exempt purposes delineated in section 501(c)(3).
This case was submitted on a stipulated administrative record under Rules 122 and 217, Tax Court Rules of Practice and Procedure. The stipulated record, which is assumed to be true…
2Cases cited21 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Browne v. CommissionerUnited States Tax Court · 1980
16 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982
- American Campaign Academy v. CommissionerUnited States Tax Court · 1989
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
- Retired Teachers Legal Defense Fund, Inc. v. CommissionerUnited States Tax Court · 1982
- Redlands Surgical Servs. v. CommissionerUnited States Tax Court · 1999
18 more not listed; retrieve them via the Exa API.