Legal Opinion
Nonprofits' Insurance Alliance of California v. United States
United States Court of Federal Claims
Decided November 10, 1994No. 93-325TPublishedCited by 4 opinions
1Opinion of the Court
OPINION
MILLER, Judge.*
This case is before the court after argument on plaintiff’s action for a declaratory judgment pursuant to 26 U.S.C. § 7428(a) (Supp. V 1993). The central question presented is whether plaintiff, an organization formed to administer a group self-insurance risk pool, qualifies for tax-exempt status under section 501(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 501(a) (1988) (the “I.R.C.”). Section 501(a) indicates that organizations described in I.R.C. § 501(c)(3) shall be exempt from taxation. First to be decided is whether plaintiff’s organization constitutes an…
2Cases cited25 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- HCSC-Laundry v. United StatesSupreme Court of the United States · 1981
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- Segel v. CommissionerUnited States Tax Court · 1987
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3Cited by4 opinions
- Family Trust of Massachusetts, Inc. v. United StatesDistrict Court, District of Columbia · 2012
- New Dynamics Foundation v. United StatesUnited States Court of Federal Claims · 2006
- Florida Independent Colleges and Universities Risk Management Association, Inc. v. Internal Revenue ServiceDistrict Court, District of Columbia · 2012
- University Medical Resident Servs., P.C. v. CommissionerUnited States Tax Court · 1996