Legal Opinion

Michigan Mobile Home & Recreational Vehicle Institute v. Commissioner

United States Tax Court

Decided July 27, 1976No. Docket No. 9097-74Published

Petitioner, a nonprofit organization for the promotion of the mobile home industry, sponsored a trade show for the display of camper and travel trailer vehicles in 1971 and 1972. Exhibition space was rented to petitioner's members and nonmembers at like rates. Subsequent to each show, petitioner made substantial space rental rebates to its member-exhibitors.

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Petitioner, a nonprofit organization for the promotion of the mobile home industry, sponsored a trade show for the display of camper and travel trailer vehicles in 1971 and 1972. Exhibition space was rented to petitioner's members and nonmembers at like rates. Subsequent to each show, petitioner made substantial space rental rebates to its member-exhibitors. Held, that petitioner failed to qualify as a tax-exempt organization under sec. 501(c)(6) for 1971 and 1972 since a part of its net earnings inured to the benefit of member-exhibitors who received space rental rebates. Held, further, that…

1Opinion of the Court

Michigan Mobile Home and Recreational Vehicle Institute, Petitioner v. Commissioner of Internal Revenue, Respondent

Michigan Mobile Home & Recreational Vehicle Institute v. Commissioner

Docket No. 9097-74

United States Tax Court

66 T.C. 770; 1976 U.S. Tax Ct. LEXIS 67;

July 27, 1976, Filed

Decision will be entered under Rule 155. 8

Petitioner, a nonprofit organization for the promotion of the mobile home industry, sponsored a trade show for the display of camper and travel trailer vehicles in 1971 and 1972. Exhibition space was rented to petitioner's members and nonmembers at like rates. Subsequent…

2Cases cited19 opinions

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  2. The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
  3. Associated Industries v. CommissionerUnited States Tax Court · 1946
  4. Crooks v. Kansas City Hay Dealers' Ass'nCourt of Appeals for the Eighth Circuit · 1929
  5. Uniform Printing & Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1937

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