Smith-Dodd Businessman's Asso. v. Commissioner
United States Tax Court
Held, the weekly operation of a bingo game by an organization exempt under sec. 501(c)(4), I.R.C. 1954, was a trade or business and the income derived therefrom is taxable as unrelated business income under secs. 511 through 513, I.R.C. 1954.
1Opinion of the Court
OPINION
Section 511(a)4 imposes a tax on income received by exempt organizations which is derived from unrelated trade or business activities. Section 513(a)5 defines the term “unrelated trade or business” generally to include any trade or business carried on by an exempt organization, the conduct of which, aside from the organization’s need to raise funds, is not substantially related to the exempt purposes of the organization. In the instant case, the evidence is clear that petitioner’s regularly conducted bingo games were a trade or business from which it derived considerable income and…
2Cases cited7 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Commissioner v. SullivanSupreme Court of the United States · 1958
- Help Children, Inc. v. CommissionerUnited States Tax Court · 1957
2 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Louisiana Credit Union League v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1982
- Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
- Clarence Labelle Post No. 217, Veterans of Foreign Wars of the United States v. United StatesCourt of Appeals for the Eighth Circuit · 1978
- Suffolk County Patrolmen's Benevolent Asso. v. CommissionerUnited States Tax Court · 1981
- Veterans of Foreign Wars, Dep't of Michigan v. CommissionerUnited States Tax Court · 1987
22 more not listed; retrieve them via the Exa API.