Kentucky Bar Foundation, Inc., etc. v. Commissioner
United States Tax Court
Petitioner, a nonprofit organization, was operated to accumulate funds for the purpose of acquiring land for and contributing to the cost of constructing the proposed Kentucky Bar Center Headquarters, which will house the offices of petitioner, the Kentucky Bar Association, a public law library, and other public areas.
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Petitioner, a nonprofit organization, was operated to accumulate funds for the purpose of acquiring land for and contributing to the cost of constructing the proposed Kentucky Bar Center Headquarters, which will house the offices of petitioner, the Kentucky Bar Association, a public law library, and other public areas. Held: Any benefit accruing to the legal profession through the activities to be conducted at the Kentucky Bar Center Headquarters is incidental to the broad charitable purposes served by those activities. Thus, petitioner is an exempt organization within the meaning of sec.…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined petitioner does not qualify for exemption from Federal income tax as an organization described in section 501(c)(3).1 Having exhausted its administrative remedies within the Internal Revenue Service as required by section 7428(b)(2), petitioner has timely invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The issue is whether petitioner is operated exclusively for exempt purposes within the meaning of section 501(c)(3).
This case was submitted for decision on the stipulated administrative record under Rule 122,…
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