South End Italian Independent Club, Inc. v. Commissioner
United States Tax Court
Petitioner, a social club exempt from tax under sec. 501(c)(7), conducted beano games pursuant to a Massachusetts license. Massachusetts law required the entire net proceeds of these beano games to be donated for charitable, religious, and educational uses. Petitioner's license could be revoked if it violated this or any other provision of Massachusetts law governing beano games.
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Petitioner, a social club exempt from tax under sec. 501(c)(7), conducted beano games pursuant to a Massachusetts license. Massachusetts law required the entire net proceeds of these beano games to be donated for charitable, religious, and educational uses. Petitioner's license could be revoked if it violated this or any other provision of Massachusetts law governing beano games. Petitioner donated the net proceeds of its beano games in accordance with the requirements of Massachusetts law. Held, petitioner's "donations" are fully deductible from its "unrelated business taxable income" as an…
1Opinion of the Court
South End Italian Independent Club, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
South End Italian Independent Club, Inc. v. Commissioner
Docket No. 35770-84
United States Tax Court
87 T.C. 168; 1986 U.S. Tax Ct. LEXIS 76; 87 T.C. No. 11;
July 22, 1986, Filed
Decision will be entered for the petitioner.
Petitioner, a social club exempt from tax under sec. 501(c)(7), conducted beano games pursuant to a Massachusetts license. Massachusetts law required the entire net proceeds of these beano games to be donated for charitable, religious, and educational uses. Petitioner's license…
2Cases cited30 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
- Nachman v. CommissionerUnited States Tax Court · 1949
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