B.S.W. Group, Inc. v. Commissioner
United States Tax Court
T is a corporation which plans as its sole activity to offer consulting services for a fee to nonprofit, limited resource organizations engaged in various rural-related activities. T's service consists of obtaining appropriate individuals to perform research projects for the clients. Some of T's clients will be exempt organizations, but others may not be exempt.
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T is a corporation which plans as its sole activity to offer consulting services for a fee to nonprofit, limited resource organizations engaged in various rural-related activities. T's service consists of obtaining appropriate individuals to perform research projects for the clients. Some of T's clients will be exempt organizations, but others may not be exempt. The fees charged by T will be set at or close to cost, but will in no event be less than T's full cost of providing its services. T will realize a projected net profit in its first year of operation. The administrative record fails to…
1Opinion of the Court
OPINION
Raum, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3), I.R.C. 1954. Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.1 The issue is whether petitioner is operated exclusively for charitable, educational, or scientific purposes within the meaning of section 501(c)(3).
This case was submitted for decision on the stipulated administrative record under Rule 122, Tax Court Rules of Practice and Procedure. The stipulated…
2Cases cited24 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
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3Cited by115 opinions
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- General Conference of Free Church v. CommissionerUnited States Tax Court · 1979
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