Legal Opinion
Sierra Club Inc. v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided June 20, 1996No. 95-70112PublishedCited by 25 opinions
1Opinion of the Court
WIGGINS, Circuit Judge:
Sierra Club, Inc., a tax-exempt organization under I.R.C. § 501(c)(4), must pay taxes on “unrelated business taxable income” (“UBTI”) under I.R.C. §§ 511-13. 1 I.R.C. § 512(b)(2), however, excludes “all royalties” from UBTI, thus rendering the royalty income of a tax-exempt organization non-taxable. The Commissioner of Internal Revenue (“Commissioner”) contends that the Tax Court erred in determining on summary judgment that Sierra Club’s income from the rental of its mailing lists and from participation in an affinity credit card program constituted “royalties” and…
2Cases cited15 opinions
- Firestone Tire & Rubber Co. v. BruchSupreme Court of the United States · 1989
- Parks School of Business, Inc., Dba Parks College, a New Mexico Corporation v. Fife Symington Roy A. Nicholson Sally HeinCourt of Appeals for the Ninth Circuit · 1995
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
- Commissioner v. SolimanSupreme Court of the United States · 1993
- United States v. American College of PhysiciansSupreme Court of the United States · 1986
10 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Schering-Plough Corp. v. Federal Trade CommissionCourt of Appeals for the Eleventh Circuit · 2005
- Taproot Administrative Services, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
- Talley Industries Inc. Consolidated Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
- Common Cause v. CommissionerUnited States Tax Court · 1999
- In Re HurdleDistrict Court, D. California · 1999
20 more not listed; retrieve them via the Exa API.