Indiana Crop Improv. Ass'n v. Commissioner
United States Tax Court
Petitioner has been delegated the responsibility of seed certification by Purdue University in accordance with Indiana and Federal law. It conducts impartial testing and research activities in fulfilling the requirements of these laws, and also conducts additional research and educational activities. Held, petitioner is organized for charitable, educational, and scientific purposes within the meaning of sec. 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Wilbur, Judge:
Respondent failed to determine whether petitioner qualifies for exemption from Federal income tax under section 501(c)(3).1 Pursuant to section 7428, petitioner has invoked jurisdiction of this Court for declaratory judgment. The statutory prerequisites for declaratory judgment have been satisfied.2 The issue for our decision is whether petitioner is organized and operated exclusively for charitable, educational, and scientific purposes within the meaning of section 501(c)(3).
This case was submitted for decision on a stipulated administrative record under Rules 122 and…
2Cases cited3 opinions
- Underwriters' Laboratories, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 1943
- Underwriters' Laboratories, Inc. v. CommissionerUnited States Board of Tax Appeals · 1942
- Professional Standards Review Organization v. CommissionerUnited States Tax Court · 1980
3Cited by5 opinions
- Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000
- Abovo Foundation, Inc. v. CommissionerUnited States Tax Court · 2018
- Indiana Crop Improv. Ass'n v. CommissionerUnited States Tax Court · 1981
- Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000
- Quality Auditing Company, Inc. v. CommissionerUnited States Tax Court · 2000