Dumaine Farms v. Commissioner
United States Tax Court
T is a perpetual, irrevocable trust organized to operate an experimental model demonstration farm in North Carolina. T conducts large-scale research projects designed to demonstrate (1) marginally arable land should be held as conservation land to improve the watershed, provide ground cover and food for wildlife, and for timber production; and (2) modern, ecologically sound farming techniques can restore to productive use land exhausted by repetitive cash-crop farming.
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T is a perpetual, irrevocable trust organized to operate an experimental model demonstration farm in North Carolina. T conducts large-scale research projects designed to demonstrate (1) marginally arable land should be held as conservation land to improve the watershed, provide ground cover and food for wildlife, and for timber production; and (2) modern, ecologically sound farming techniques can restore to productive use land exhausted by repetitive cash-crop farming. T will keep the public and the farming community informed about its activities and will be open to the public on a partially…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined petitioner does not qualify for exemption from Federal income tax under section 501(a)1 as an organization described in section 501(c)(3). Having exhausted its administrative remedies as required by section 7428(b)(2), petitioner has timely challenged respondent’s determination and invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428(a). The issues are whether petitioner is organized and operated exclusively for scientific, educational, or charitable purposes, and whether petitioner is operated for private benefit.
Th…
2Cases cited43 opinions
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