Coastal Club, Inc. v. Commissioner
United States Tax Court
By transactions entered into for profit petitioner, a corporation, organized as a duck-hunting club, repeatedly leased its property for the exploration for and production of oil and gas.
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By transactions entered into for profit petitioner, a corporation, organized as a duck-hunting club, repeatedly leased its property for the exploration for and production of oil and gas. During the years in issue the oil and gas income predominantly exceeded the amounts received from its members in the form of dues, and service and guest charges, and supplied from in excess of two-thirds to as much as four-fifths of the amounts required and expended for operations, repairs, maintenance, and improvements. And not only that but through such income plus the interest from U.S. Government bonds in…
1Opinion of the Court
The respondent determined deficiencies in income tax against the petitioner for its fiscal years ended March 31, 1957 through 1960, in the respective amounts of $143,464.26, $54,020.40, $40,039.28, and $6,989.87.
The questions presented are (1) whether for the taxable years petitioner was a recreational club entitled to exemption from tax under section 501(c)(7) of the Internal Revenue Code of 1954; and (2) alternatively, whether the respondent abused his discretion in revoking his prior ruling that petitioner was exempt.
FINDINGS OF FACT
Some of the facts have been stipulated and are found as…
2Cases cited21 opinions
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- United States v. StewartSupreme Court of the United States · 1940
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- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Bank of Commerce v. Tennessee Ex Rel. MemphisSupreme Court of the United States · 1896
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3Cited by11 opinions
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- Minnequa University Club v. CommissionerUnited States Tax Court · 1971
- Polish American Club, Inc. v. CommissionerUnited States Tax Court · 1974
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