Ford Dealers Advertising Fund, Inc. v. Commissioner
United States Tax Court
Petitioner, a nonprofit corporation, received funds from Ford Motor Co. auto dealers which, under a written agreement, were to be expended solely for the not-for-profit purposes of the fund in advertising and promoting the automotive products and services of the members. Petitioner also received funds from Ford Motor Co. which were to be expended solely "for advertising."
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Petitioner, a nonprofit corporation, received funds from Ford Motor Co. auto dealers which, under a written agreement, were to be expended solely for the not-for-profit purposes of the fund in advertising and promoting the automotive products and services of the members. Petitioner also received funds from Ford Motor Co. which were to be expended solely "for advertising." Held, petitioner held all funds in "trust," and could realize no gain or profit as a result of their receipt; hence said funds are not includable in petitioner's "gross income."
1Opinion of the Court
Foeeestek, Judge:
Respondent has determined deficiencies in petitioner’s Federal income tax for the taxable years ending January 81, 1966, and January 31,1967, in the amounts of $97,514.85 and $83,150.54, respectively.
Concessions having been made, the only issue remaining for decision is whether funds received by the Ford Dealers Advertising Fund, Inc., from its members and Ford Motor Co. are includable in “gross income.”
findings of fact
Some of the facts have been stipulated. The stipulation and exhibits attached thereto are incorporated herein by this reference.
Petitioner herein is the Ford…
2Cases cited6 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Chicago, Milwaukee & St. Paul Railway Co. v. Des Moines Union Railway Co.Supreme Court of the United States · 1920
- Broadcast Measurement Bureau, Inc. v. CommissionerUnited States Tax Court · 1951
- Angelus Funeral Home v. CommissionerUnited States Tax Court · 1967
- Angelus Funeral Home v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1969
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