Kentucky Municipal League v. Commissioner
United States Tax Court
L, an exempt civic league, collected certain unpaid taxes for member municipalities in exchange for 50 percent of the amounts collected. L engaged G to assist in the collection of such taxes. Held, the amount of taxes retained by L does not constitute unrelated business taxable income within the meaning of sec. 512(a)(1), I.R.C. 1954.
1Opinion of the Court
OPINION
Simpson, Judge:
The Commissioner determined a deficiency of $4,373 in the petitioner’s Federal income tax for the fiscal year ended June 30,1977. After a concession by the petitioner, the sole issue for decision is whether funds received by the petitioner from the collection of unpaid taxes for its members constitute unrelated business taxable income within the meaning of section 512(a)(1) of the Internal Revenue Code of 1954.1
All of the facts have been stipulated, and those facts are so found.
The petitioner, Kentucky Municipal League (the league), is a nonprofit organization, with its…
2Cases cited8 opinions
- Professional Ins. Agents v. CommissionerUnited States Tax Court · 1982
- Carolinas Farm & Power Equipment Dealers Association, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1983
- Associated Master Barbers & Beauticians, Inc. v. CommissionerUnited States Tax Court · 1977
- United States v. Pickwick Electric Membership Corp.Court of Appeals for the Sixth Circuit · 1946
- Hi-Plains Hospital v. United StatesCourt of Appeals for the Fifth Circuit · 1982
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3Cited by3 opinions
- S.S. Trade Asso. v. CommissionerUnited States Tax Court · 1983
- Kentucky Municipal League v. CommissionerUnited States Tax Court · 1983
- S.S. Trade Asso. v. CommissionerUnited States Tax Court · 1983