Greater United Navajo Dev. Enters. v. Commissioner
United States Tax Court
P is a corporation organized to benefit the poor of the Navajo Nation by assisting in the organization and operation of businesses that employ or are owned by residents of the Navajo Reservation.
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P is a corporation organized to benefit the poor of the Navajo Nation by assisting in the organization and operation of businesses that employ or are owned by residents of the Navajo Reservation. In 1974, P received a large grant from the Federal Government, although no further grants have been received; currently, P's most substantial source of revenue is the leasing of oil well drilling equipment, an enterprise operated outside the Navajo Reservation through a private, independent for-profit organization, Madar, Inc. The record does not show that any members of the Navajo Nation are…
1Opinion of the Court
Raum, Judge:
The Commissioner has ruled that petitioner does not qualify for exemption from income taxation under section 501(c)(3), I.R.C. 1954. Petitioner invokes the jurisdiction of this Court pursuant to section 7428 to obtain a declaratory judgment as to its exempt status.1 The question presented is whether petitioner is organized and operated exclusively for charitable purposes within the meaning of section 501(c)(3), I.R.C. 1954.
FINDINGS OF FACT
This case was submitted on the basis of the stipulated administrative record, which is hereby incorporated in these findings by reference.…
2Cases cited33 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- Helvering v. BlissSupreme Court of the United States · 1934
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
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3Cited by17 opinions
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- P.L.L. Scholarship Fund v. CommissionerUnited States Tax Court · 1984
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