West Virginia State Medical Asso. v. Commissioner
United States Tax Court
P, a medical association exempt from income tax under sec. 501(c)(6), I.R.C. 1954, publishes a medical journal as part of its exempt purpose. P sells advertising within such journal. Direct advertising costs of the journal exceeded gross advertising revenue. P also receives revenue, distinct from its advertising revenue, in the form of commissions for endorsing and marketing the services of a third party.
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P, a medical association exempt from income tax under sec. 501(c)(6), I.R.C. 1954, publishes a medical journal as part of its exempt purpose. P sells advertising within such journal. Direct advertising costs of the journal exceeded gross advertising revenue. P also receives revenue, distinct from its advertising revenue, in the form of commissions for endorsing and marketing the services of a third party. Held: 1. To compute its unrelated business taxable income, P may offset the income from its endorsement activities with the losses from its advertising activities only if the advertising…
1Opinion of the Court
OPINION
FAY, Judge:
These cases were assigned to Special Trial Judge Hu S. Vandervort pursuant to the provisions of section 7456(d)(3) of the Code (redesignated section 7443A(b)(3) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
VANDERVORT, Special Trial Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for its 1983 taxable year, in the…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Golanty v. CommissionerUnited States Tax Court · 1979
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
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3Cited by10 opinions
- National Water Well Ass'n v. CommissionerUnited States Tax Court · 1989
- National Collegiate Athletic Ass'n v. CommissionerUnited States Tax Court · 1989
- West Virginia State Medical Association v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1989
- National Ass'n of Life Underwriters v. CommissionerUnited States Tax Court · 1992
- Nat'l Educ. Ass'n of the United States v. Comm'rUnited States Tax Court · 2011
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