North American Sequential Sweepstakes v. Commissioner
United States Tax Court
Petitioner was organized to conduct a skydiving competition based upon a novel form of team skydiving in which its creators were interested. All of petitioner's creators participated in the competition, and petitioner financially supported one of their teams' participation in an international competition. Held, petitioner was not operated exclusively for exempt purposes within the meaning of sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Wiles, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Petitioner, challenging respondent’s adverse determination, has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The sole issue for decision is whether petitioner was operated exclusively for one or more exempt purposes within the meaning of section 501(c)(3).
This case was submitted for decision on the basis of the certified administrative record under Rule 217(b), Tax Court Rules of…
2Cases cited10 opinions
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- Federation Pharmacy Services, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1980
- Baltimore Regional Joint Board Health & Welfare Fund v. CommissionerUnited States Tax Court · 1978
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