Anderson Country Club, Inc. v. Commissioner
United States Tax Court
Petitioner was incorporated under the Indiana Business Corporations Act in 1921 to act as the successor to an unincorporated association formed in 1902 for the purpose of constructing and operating a golf course and country club. The golf course and club house were located on a tract of land leased by the association. Upon the expiration of the lease the owners of the land demanded such an increase in rental upon renewal that it was decided to buy the land.
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Petitioner was incorporated under the Indiana Business Corporations Act in 1921 to act as the successor to an unincorporated association formed in 1902 for the purpose of constructing and operating a golf course and country club. The golf course and club house were located on a tract of land leased by the association. Upon the expiration of the lease the owners of the land demanded such an increase in rental upon renewal that it was decided to buy the land. It was necessary to buy the entire tract, including some acreage which proved to be unsuitable for a golf course. Petitioner's attempts…
1Opinion of the Court
OPINION.
Kern, Judge:
The only issue presented for our decision is whether petitioner is exempt under section 101 (9) of the Internal Revenue Code, as a club “organized and operated exclusively for pleasure, recreation and other non-profitable purposes, no part of the net earnings of which inures to the benefit of any private shareholder.”
Respondent contends that petitioner should be denied the exemption for two reasons: The fact that it sold, at a profit, certain real estate ; and, though this is urged much less strenuously, the fact that some profit was realized by petitioner in 1936 and 1937…
2Cited by18 opinions
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- Coastal Club, Inc. v. CommissionerUnited States Tax Court · 1965
- Polish Army Veterans Post 147 v. CommissionerUnited States Tax Court · 1955
- Debs Memorial Radio Fund, Inc. v. CommissionerUnited States Tax Court · 1944
- Mill Lane Club, Inc. v. CommissionerUnited States Tax Court · 1954
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