Legal Opinion

Nationalist Movement v. Commissioner

United States Tax Court

Decided April 11, 1994No. Docket No. 10540-91XPublishedCited by 26 opinions

P, an organization seeking tax-exempt status under sec. 501(c)(3), I.R.C., advocates social, economic, and political change in the United States. Among its activities are the publication and distribution of a monthly newsletter, the production of a cable television program, the conducting of a telephone counseling service, and participation in public events such as speeches, rallies, and parades. P also engages in litigation activities.

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P, an organization seeking tax-exempt status under sec. 501(c)(3), I.R.C., advocates social, economic, and political change in the United States. Among its activities are the publication and distribution of a monthly newsletter, the production of a cable television program, the conducting of a telephone counseling service, and participation in public events such as speeches, rallies, and parades. P also engages in litigation activities. R rejected P's application for exemption on the grounds that P does not operate exclusively for charitable or educational purposes and that P operates in…

1Opinion of the Court

OPINION

Hamblen, Chief Judge:

Respondent determined that petitioner, The Nationalist Movement (sometimes abbreviated as tnm), does not qualify for exemption from Federal income taxation under section 501(c)(3).1 Petitioner has challenged respondent’s determination by invoking the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The parties agree that petitioner has exhausted the administrative remedies available within the Internal Revenue Service (irs) and has timely filed its petition in this Court. See sec. 7428(b).

A preliminary issue for decision is: (1)…

2Cases cited73 opinions

  1. Grayned v. City of RockfordSupreme Court of the United States · 1972
  2. Broadrick v. OklahomaSupreme Court of the United States · 1973
  3. Hoffman Estates v. Flipside, Hoffman Estates, Inc.Supreme Court of the United States · 1982
  4. Kolender v. LawsonSupreme Court of the United States · 1983
  5. Bolling v. SharpeSupreme Court of the United States · 1954

68 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Redlands Surgical Servs. v. CommissionerUnited States Tax Court · 1999
  2. Stepnowski v. Comm'rUnited States Tax Court · 2005
  3. Quality Auditing Co. v. CommissionerUnited States Tax Court · 2000
  4. Rameses Sch. v. Comm'rUnited States Tax Court · 2007
  5. 6611, Ltd. v. Comm'rUnited States Tax Court · 2013

21 more not listed; retrieve them via the Exa API.

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