Hutchinson Baseball Enterprises, Inc. v. Commissioner
United States Tax Court
Petitioner's advance ruling that it was exempt within meaning of sec. 501(c)(3), I.R.C. 1954, revoked on grounds that it was "not organized and operated for a charitable purpose." Petitioner's articles of incorporation provided that its purpose was to promote, advance, and sponsor baseball, including little league and amateur baseball, in designated area. Its main activity was funding and operating a baseball team, the Hutchinson Broncos.
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Petitioner's advance ruling that it was exempt within meaning of sec. 501(c)(3), I.R.C. 1954, revoked on grounds that it was "not organized and operated for a charitable purpose." Petitioner's articles of incorporation provided that its purpose was to promote, advance, and sponsor baseball, including little league and amateur baseball, in designated area. Its main activity was funding and operating a baseball team, the Hutchinson Broncos. Held: Petitioner is entitled to sec. 501(c)(3) exemption. Purpose cited above qualifies as an exempt organizational purpose. Broncos was an amateur team…
1Opinion of the Court
OPINION
Sterrett, Judge:
Respondent, on August 28, 1978, issued a final adverse determination with respect to petitioner’s exempt status under section 501(c)(3), I.R.C. 1954. This is an action for declaratory relief under the terms of section 7428.
The administrative record, which includes all the facts upon which respondent made his final adverse determination, was submitted to this Court under Rule 217(b)(1), Tax Court Rules of Practice and Procedure, and is incorporated herein by this reference. The facts and representations contained in the record are assumed to be true for purposes of this…
2Cases cited4 opinions
- 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
- Peters v. CommissionerUnited States Tax Court · 1953
- Mobile Arts and Sports Association v. United StatesDistrict Court, S.D. Alabama · 1957
3Cited by10 opinions
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
- Hutchinson Baseball Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1982
- North American Sequential Sweepstakes v. CommissionerUnited States Tax Court · 1981
- GameHearts v. Comm'rUnited States Tax Court · 2015
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
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