Presbyterian & Reformed Pub. Co. v. Commissioner
United States Tax Court
Petitioner, a publisher of religious materials, was granted tax-exempt status in 1939 under sec. 101(6), I.R.C. 1939. Between 1975 and 1979, petitioner's sales, profits, and cash accumulations were significant; it began paying royalties to authors; its staff changed from volunteers to paid employees; it engaged in selling and buying books with other publishing companies; it increasingly adopted a commercial method of operation.
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Petitioner, a publisher of religious materials, was granted tax-exempt status in 1939 under sec. 101(6), I.R.C. 1939. Between 1975 and 1979, petitioner's sales, profits, and cash accumulations were significant; it began paying royalties to authors; its staff changed from volunteers to paid employees; it engaged in selling and buying books with other publishing companies; it increasingly adopted a commercial method of operation. The District Director of Internal Revenue informed petitioner of the possible revocation of its exempt status in 1978 and the Commissioner issued a final determination…
1Opinion of the Court
Featherston, ,Judge:1
'Respondent retroactively revoked petitioner’s status as an organization exempt from Federal income tax under sections 501(a) and 501(c)(3).2 Petitioner challenges respondent’s revocation and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issues presented are whether petitioner was operated exclusively for an exempt purpose within the meaning of section 501(c)(3), and, if not, whether the Commissioner abused his discretion in making revocation retroactive to January 1,1969.
FINDINGS OF FACT3
At the time it filed the…
2Cases cited24 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
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Christian Echoes National Ministry, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1973
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3Cited by24 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Miedaner v. CommissionerUnited States Tax Court · 1983
- Elkins v. CommissionerUnited States Tax Court · 1983
- Virginia Education Fund v. CommissionerUnited States Tax Court · 1985
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