Underwriters' Laboratories, Inc. v. Commissioner
United States Board of Tax Appeals
1. Upon the evidence, held, petitioner is not entitled to exemption as a charitable, scientific, or educational corporation, as it was not organized and operated exclusively for such purposes and a part of its earnings inured to the benefit of private shareholders and individuals; held, further, it is not entitled to exemption as a business league, part of its earnings having inured to the benefit of private shareholders and individuals. 2. Held, petitioner is not entitled…
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1. Upon the evidence, held, petitioner is not entitled to exemption as a charitable, scientific, or educational corporation, as it was not organized and operated exclusively for such purposes and a part of its earnings inured to the benefit of private shareholders and individuals; held, further, it is not entitled to exemption as a business league, part of its earnings having inured to the benefit of private shareholders and individuals. 2. Held, petitioner is not entitled to a deduction as a business expense of an amount paid on account of premium for employees' pension and disability policy…
1Opinion of the Court
*471OPINION.
Arnold :
It is contended by petitioner that it is exempt from Federal income and excess profits taxes and surtax on undistributed profits either as a nonprofit corporation organized and operated exclusively for charitable, educational, or scientific purposes or as a business league, no part of the net earnings of which inures to the benefit of any private stockholder or individual. Sec. 101 (6) and (7), Revenue Acts of 1936 and 1938.1
*472It is not controlling that the petitioner was organized under the laws of Delaware as a nonprofit corporation, that it represented or aimed to furnish…
2Cases cited4 opinions
- Cannon Manufacturing Co. v. Cudahy Packing Co.Supreme Court of the United States · 1925
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Peterson v. Chicago, Rock Island & Pacific Railway Co.Supreme Court of the United States · 1907
- Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877
3Cited by14 opinions
- Bianchi v. CommissionerUnited States Tax Court · 1976
- Consumers Credit Rural Electric Cooperative Corp. v. CommissionerUnited States Tax Court · 1961
- MIB, Inc. v. CommissionerUnited States Tax Court · 1983
- Partners in Charity, Inc. v. CommissionerUnited States Tax Court · 2013
- Indiana Crop Improv. Ass'n v. CommissionerUnited States Tax Court · 1981
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