Legal Opinion

Association of The Bar v. Commissioner

United States Tax Court

Decided September 17, 1987No. Docket No. 6715-86XPublished

Petitioner seeks a declaratory judgment from respondent's adverse final determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954. Respondent determined that petitioner is an "action" organization, as defined in sec. 1.501(c)(3)-1(c)(3)(iii), Income Tax Regs., because petitioner's practice of rating candidates for elective judicial offices constitutes participation or intervention in any political campaign on behalf of any candidate for…

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Petitioner seeks a declaratory judgment from respondent's adverse final determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954. Respondent determined that petitioner is an "action" organization, as defined in sec. 1.501(c)(3)-1(c)(3)(iii), Income Tax Regs., because petitioner's practice of rating candidates for elective judicial offices constitutes participation or intervention in any political campaign on behalf of any candidate for public office, within the meaning of sec. 501(c)(3). Held, the mere act of rating candidates for judicial office, without…

1Opinion of the Court

The Association of the Bar of the City of New York, Petitioner v. Commissioner of Internal Revenue, Respondent

Association of The Bar v. Commissioner

Docket No. 6715-86X

United States Tax Court

89 T.C. 599; 1987 U.S. Tax Ct. LEXIS 132; 89 T.C. No. 42;

September 17, 1987; As amended October 1, 1987; As amended September 24, 1987; Reversed September 27, 1988 September 17, 1987, Filed

Petitioner seeks a declaratory judgment from respondent's adverse final determination that petitioner is not an organization described in sec. 501(c)(3), I.R.C. 1954. Respondent determined that petitioner is an "action"…

Also in this document: Dissent · Chabot; Dissent · Jacobs.

2Cases cited14 opinions

  1. Cammarano v. United StatesSupreme Court of the United States · 1959
  2. Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
  3. Church of Scientology of California v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  4. Church of Scientology v. CommissionerUnited States Tax Court · 1984
  5. Christian Echoes National Ministry, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1973

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