Legal Opinion

CORE Special Purpose Fund v. Commissioner

United States Tax Court

Decided January 30, 1985No. Docket No. 20862-80Unpublished

P is an organization exempt from taxation under sec. 501(c)(3), I.R.C. 1954. P derived unrelated business income from the sale of advertising space in its two magazines and incurred expenses in the telephone solicitation of the advertising and in the publication of the magazines.

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P is an organization exempt from taxation under sec. 501(c)(3), I.R.C. 1954. P derived unrelated business income from the sale of advertising space in its two magazines and incurred expenses in the telephone solicitation of the advertising and in the publication of the magazines. Held, P has failed to prove that certain expenses which it deducted in calculating its unrelated business taxable income were incurred, or if incurred, were "directly connected with" its unrelated advertising activity within the meaning of sec. 512(a), I.R.C. 1954. However, P is entitled to deduct a portion of its…

1Opinion of the Court

CORE SPECIAL PURPOSE FUND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

CORE Special Purpose Fund v. Commissioner

Docket No. 20862-80.

United States Tax Court

T.C. Memo 1985-48; 1985 Tax Ct. Memo LEXIS 585; 49 T.C.M. (CCH) 626; T.C.M. (RIA) 85048;

January 30, 1985

P is an organization exempt from taxation under sec. 501(c)(3), I.R.C. 1954. P derived unrelated business income from the sale of advertising space in its two magazines and incurred expenses in the telephone solicitation of the advertising and in the publication of the magazines. Held, P has failed to prove that certain…

2Cases cited28 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  5. Burnet v. HoustonSupreme Court of the United States · 1931

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