Miss Georgia Scholarship Fund, Inc. v. Commissioner
United States Tax Court
The petitioner was set up to provide a fund for the purpose of giving scholarships to contestants in the Miss Georgia Pageant.
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The petitioner was set up to provide a fund for the purpose of giving scholarships to contestants in the Miss Georgia Pageant. The participants were required as a condition for qualifying for scholarships to enter into a contract which would obligate them in the event they were selected to participate in the Miss America Pageant to abide by the rules and regulations of the pageants, including participation in public appearances and the like, under the sponsorship of the Miss Georgia Pageant. Held: The only activity engaged in by the petitioner was the awarding of so-called scholarships to…
1Opinion of the Court
OPINION
Quealy, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue presented to us is whether petitioner is operated exclusively for charitable, religious, or educational purposes within the meaning of section 501(c)(3) of the Code.
This case was submitted for decision on the stipulated administrative record under Rule 122, Tax Court Rules of Practice and Procedure.…
2Cases cited8 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- 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
- Phillip L. Parr and Barbara M. Parr v. United States of America, James David Emerson and Nancy M. Emerson v. United StatesCourt of Appeals for the Fifth Circuit · 1972
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3Cited by5 opinions
- Ohio Teamsters Educational & Safety Training Trust Fund v. CommissionerUnited States Tax Court · 1981
- Local Union 712, I. B. E. W. Scholarship Trust Fund v. CommissionerUnited States Tax Court · 1983
- Lopez v. Comm'rUnited States Tax Court · 2017
- Miss Georgia Scholarship Fund, Inc. v. CommissionerUnited States Tax Court · 1979
- Ohio Teamsters Educational & Safety Training Trust Fund v. CommissionerUnited States Tax Court · 1981