Piety, Inc. v. Commissioner
United States Tax Court
Petitioner seeks a declaratory judgment that it is exempt from taxation under sec. 501(c)(3), I.R.C. 1954. Petitioner's sole activity is the operation of bingo games. It intends to contribute its profits to exempt organizations. Held, petitioner may not qualify for exemption on the ground that it will donate its profits to exempt organizations.
1Opinion of the Court
Piety, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Piety, Inc. v. Commissioner
Docket No. 28128-82X
United States Tax Court
82 T.C. 193; 1984 U.S. Tax Ct. LEXIS 114; 82 T.C. No. 16;
January 26, 1984, Filed
Decision will be entered for the respondent.
Petitioner seeks a declaratory judgment that it is exempt from taxation under sec. 501(c)(3), I.R.C. 1954. Petitioner's sole activity is the operation of bingo games. It intends to contribute its profits to exempt organizations. Held, petitioner may not qualify for exemption on the ground that it will donate its profits to exempt…
2Cases cited4 opinions
- Smith-Dodd Businessman's Asso. v. CommissionerUnited States Tax Court · 1975
- Industrial Aid for the Blind v. CommissionerUnited States Tax Court · 1979
- P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
- Piety, Inc. v. CommissionerUnited States Tax Court · 1984