Legal Opinion

Santa Barbara Club v. Commissioner

United States Tax Court

Decided May 23, 1977No. Docket No. 8544-74Published

Petitioner, a corporation organized as a social club, sold bottled liquor to its members for consumption away from the club's premises. For each year in issue, such sales exceeded 25 percent of the club's total gross receipts. Held, petitioner was not operated exclusively for exempt purposes and did not qualify for tax exemption under sec. 501(c)(7), I.R.C. 1954.

1Opinion of the Court

Santa Barbara Club, Petitioner v. Commissioner of Internal Revenue, Respondent

Santa Barbara Club v. Commissioner

Docket No. 8544-74

United States Tax Court

68 T.C. 200; 1977 U.S. Tax Ct. LEXIS 107;

May 23, 1977, Filed

Decision will be entered for the respondent.

Petitioner, a corporation organized as a social club, sold bottled liquor to its members for consumption away from the club's premises. For each year in issue, such sales exceeded 25 percent of the club's total gross receipts. Held, petitioner was not operated exclusively for exempt purposes and did not qualify for tax exemption under sec.…

Also in this document: Dissent.

2Cases cited31 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Glidden Co. v. ZdanokSupreme Court of the United States · 1962
  3. Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
  4. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  5. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960

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