American Campaign Academy v. Commissioner
United States Tax Court
P is organized to pursue educational and charitable activities. As its primary activity, P operates a school to train individuals to fill responsible positions in political campaigns. P's training program is an "outgrowth" of similar training programs previously sponsored by the National Republican Congressional Committee.
Read the full summary
P is organized to pursue educational and charitable activities. As its primary activity, P operates a school to train individuals to fill responsible positions in political campaigns. P's training program is an "outgrowth" of similar training programs previously sponsored by the National Republican Congressional Committee. Graduates of P's training program are prepared to function in such strategic campaign positions as communications director, finance director, or campaign manager. Approximately 80 percent of P's graduates participated in at least 98 campaigns of Congressional and Senatorial…
1Opinion of the Court
OPINION
Nims, Chief Judge:
Petitioner seeks a declaratory judgment under section 7428(a)1 that it is exempt from Federal income taxation under section 501(a) as an organization meeting the requirements of section 501(c)(3). Further, should we declare petitioner to satisfy the requirements of section 501(c)(3), we are requested to also determine whether petitioner is classified as “other than a private foundation” by reason of sections 509(a)(1) and 170(b)(1)(A)(ii). Based upon our holding that petitioner is nonexempt under section 501(c)(3), we do not reach the latter issue.
Pursuant to Rule…
2Cases cited30 opinions
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- United States v. CorrellSupreme Court of the United States · 1967
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
25 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
- Nationalist Movement v. CommissionerUnited States Tax Court · 1994
- Redlands Surgical Servs. v. CommissionerUnited States Tax Court · 1999
- Florida Hosp. Trust Fund v. CommissionerUnited States Tax Court · 1994
- Baker v. Comm'rUnited States Tax Court · 2004
- Fund for the Study of Economic Growth & Tax Reform v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1998
48 more not listed; retrieve them via the Exa API.