Legal Opinion

Partners In Charity Inc. v. Commissioner

United States Tax Court

Decided August 26, 2013No. 1701-11XPublished

1Opinion of the Court

141 T.C. No. 2

UNITED STATES TAX COURT PARTNERS IN CHARITY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1701-11X. Filed August 26, 2013. P was established as a nonprofit corporation under the laws of Illinois. P applied for recognition of tax-exempt status, explaining that its primary activity was to provide down-payment assistance grants to home buyers. R determined that P was a charitable organization described in I.R.C. sec. 501(c)(3). In actual operation, P required each home seller to pay to P the down-payment amount along with a fee. R retroactively…

2Cases cited16 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  3. B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
  4. Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
  5. Scripture Press Foundation v. United StatesUnited States Court of Claims · 1961

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