Christian Manner International, Inc. v. Commissioner
United States Tax Court
Petitioner was organized pursuant to the Nonprofit Corporation Act of Texas. Its articles of incorporation indicate that the purposes for its organization were religious, charitable, and educational in nature. Petitioner's primary activity was the publication and sale of books written by its founder which were religiously inspired and oriented but were sold commercially at a profit.
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Petitioner was organized pursuant to the Nonprofit Corporation Act of Texas. Its articles of incorporation indicate that the purposes for its organization were religious, charitable, and educational in nature. Petitioner's primary activity was the publication and sale of books written by its founder which were religiously inspired and oriented but were sold commercially at a profit. Held, respondent did not err in denying petitioner's application for exemption under section 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent determined that petitioner does not qualify for exemption for Federal income tax under section 501(c)(3), I.R.C. 1954.1 Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue presented to us is whether petitioner is operated exclusively for charitable, religious, or educational purposes within the meaning of section 501(c)(3) of the Code.
This case was submitted for decision on the stipulated administrative record under-Rule 122, Tax Court Rules of Practice…
2Cases cited8 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
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- United States v. Edward I. Eiland, Trustee in Bankruptcy of Sport Coal Company, Inc., a Corporation, BankruptCourt of Appeals for the Fourth Circuit · 1955
- Scripture Press Foundation v. United StatesUnited States Court of Claims · 1961
- Pulpit Resource v. CommissionerUnited States Tax Court · 1978
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