Connecticut Theater Foundation, Inc. v. Brown

In 1973, the plaintiff, a nonstock, nonprofit Connecticut corporation, commenced operation of the Westport Country Playhouse, a summer theater. Shortly after the beginning of its 1973 season the plaintiff applied to the Connecticut tax department for an exemption from the admissions tax imposed under chapter 225 of the General Stat ntes. It also applied to the Internal Revenue Service (IRS) for exemption from the federal income tax. In April, 1974, the IRS granted the plaintiff the requested exemption effective “from the date of its inception,” which covered the commencement of the…