Legal Opinion

Appeal of Waynesboro Manufacturers Ass'n

United States Board of Tax Appeals

Decided March 30, 1925No. Docket No. 1277PublishedCited by 8 opinions

1Opinion of the Court

*914OPINION.

Sternhagen :

Both parties agree that the taxpayer was a business league, but they do not agree whether it was one “ not organized for profit and no part of the net earnings of which inures to the benefit of any private stockholder or individual,” and therefore exempt by the statute.

Like all other statutes, this provision must be construed so as to give effect to its intendment. But since it is an exemption, it must be strictly construed, and the taxpayer must establish clearly that it comes squarely within its provisions.

The language of this exemption is, for purposes of construction,…

2Cases cited1 opinion

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924

3Cited by8 opinions

  1. District of Columbia v. Mt. Vernon SeminaryCourt of Appeals for the D.C. Circuit · 1938
  2. Cape Henry Syndicate v. CommissionerUnited States Board of Tax Appeals · 1934
  3. National Chiropractic Ass'n v. BirminghamDistrict Court, N.D. Iowa · 1951
  4. Manus-Muller & Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Fruit Growers Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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