University Hill Foundation v. Commissioner
United States Tax Court
Petitioner was organized in 1945 as a nonprofit corporation under the laws of the State of California to raise funds for Loyola University of Los Angeles, and has been operated for that purpose up to the present time. It was ruled exempt from Federal income tax until 1956, when the exemption was revoked.
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Petitioner was organized in 1945 as a nonprofit corporation under the laws of the State of California to raise funds for Loyola University of Los Angeles, and has been operated for that purpose up to the present time. It was ruled exempt from Federal income tax until 1956, when the exemption was revoked. Over the 1947-54 period, petitioner purchased a number of going businesses and leased the assets to newly formed operating companies in which the former owners acquired minority interests. Held, petitioner was not a "feeder organization" as defined in sec. 502, I.R.C. 1954. Held, further,…
1Opinion of the Court
TanNENWAld, Judge:
These consolidated proceedings involve income and excess profits taxes for the fiscal years ended April 30,1952, through April 30, 1965, in the aggregate amount of $10,070,677.25. The principal questions in issue are whether petitioner is exempt from Federal income tax under sections 501(c) (3) of the 1954 Code and 101 (6) of the 1939 Code; whether petitioner is a “feeder organization” within the meaning of sections 502 and 101 of the 1954 and 1939 Codes, respectively; and what part, if any, of petitioner’s income is taxable as “unrelated business taxable income” within the…
2Cases cited35 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Commissioner v. BrownSupreme Court of the United States · 1965
- Flora v. United StatesSupreme Court of the United States · 1958
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
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3Cited by28 opinions
- Edward Orton, Jr., Ceramic Foundation v. CommissionerUnited States Tax Court · 1971
- University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Associated Hospital Services, Inc. v. CommissionerUnited States Tax Court · 1980
- Kern County Electrical Pension Fund v. CommissionerUnited States Tax Court · 1991
- AMERCO v. CommissionerUnited States Tax Court · 1984
23 more not listed; retrieve them via the Exa API.