Ohio Teamsters Educational & Safety Training Trust Fund v. Commissioner
United States Tax Court
P is a trust created under a collective bargaining agreement between the Teamsters Union (U) and the Contractors Association (A). When operational, P proposes to award grants to eligible employees and their families for the purpose of furthering their education. P's only source of funds is contributions received from members of A under the terms of the collective bargaining agreement.
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P is a trust created under a collective bargaining agreement between the Teamsters Union (U) and the Contractors Association (A). When operational, P proposes to award grants to eligible employees and their families for the purpose of furthering their education. P's only source of funds is contributions received from members of A under the terms of the collective bargaining agreement. During the negotiations between A and U prior to the completion of the collective bargaining agreement, representatives of U requested the establishment of P as part of the allocation of an agreed financial…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined that petitioner does not qualify for exemption from income taxation as an organization described in section 501(c)(3), I.R.C. 1954, and petitioner has invoked the jurisdiction of this Court to obtain a declaratory judgment as to its exempt status.1 The questions presented are whether petitioner is organized exclusively for exempt purposes; whether petitioner is operated for private, rather than public, interests; and whether petitioner’s earnings inure to the benefit of private individuals.
The case was submitted on the basis of the stipulated…
2Cases cited20 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Bingler v. JohnsonSupreme Court of the United States · 1969
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Est of Hawaii v. CommissionerUnited States Tax Court · 1979
- American Institute for Economic Research v. The United StatesUnited States Court of Claims · 1962
15 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Ohio Teamsters Educational and Safety Training Trust Fund v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
- Kentucky Bar Foundation, Inc., etc. v. CommissionerUnited States Tax Court · 1982
- North American Sequential Sweepstakes v. CommissionerUnited States Tax Court · 1981
- Local Union 712, I. B. E. W. Scholarship Trust Fund v. CommissionerUnited States Tax Court · 1983
- Policemen's Benevolent Asso. v. CommissionerUnited States Tax Court · 1981
7 more not listed; retrieve them via the Exa API.