Debs Memorial Radio Fund, Inc. v. Commissioner
United States Tax Court
1. A New York stock corporation, the successor of an unincorporated association organized as a memorial and operating a radio as a free public forum for the dissemination of liberal and progressive social views, but organized as a business corporation with wide business purposes and actually operating a commercial business in a competitive field, the income of which was used in part to pay interest on loans, which loans were payable out of surplus, and the profits of which…
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1. A New York stock corporation, the successor of an unincorporated association organized as a memorial and operating a radio as a free public forum for the dissemination of liberal and progressive social views, but organized as a business corporation with wide business purposes and actually operating a commercial business in a competitive field, the income of which was used in part to pay interest on loans, which loans were payable out of surplus, and the profits of which were used and destined to support its commercial as well as welfare functions, is not tax exempt as a civic organization…
1Opinion of the Court
OPINION.
Sternhagen, Judge'.
1. The petitioner claims exemption from excess profits tax by virtue of section 727, Internal Revenue Code, as a corporation exempt from income tax under section 101 (8): “Civic leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare * * Regulations 103, section 19.101 (8) — 1, provides: “Civic leagues entitled to exemption under section 101 (8) comprise those not organized for profit but operated exclusively for purposes beneficial to the community as a whole, and, in general, include organizations engaged in…
Also in this document: Concurrence.
2Cases cited3 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Anderson Country Club, Inc. v. CommissionerUnited States Tax Court · 1943
- Associated Music Publishers, Inc. v. Debs Memorial Radio Fund, Inc.District Court, S.D. New York · 1942
3Cited by8 opinions
- Debs Memorial Radio Fund v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1945
- People's Educational Camp Soc. v. CommissionerUnited States Tax Court · 1963
- Lake Forest, Inc. v. CommissionerUnited States Tax Court · 1961
- Debs Memorial Radio Fund v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1945
- Debs Memorial Radio Fund, Inc. v. CommissionerUnited States Tax Court · 1944
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