Legal Opinion
North Ridge Country Club v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided June 6, 1989No. 88-7062PublishedCited by 9 opinions
1Opinion of the Court
LEAVY, Circuit Judge:
OVERVIEW
The Commissioner of Internal Revenue (“the Commissioner”) appeals a tax court decision rejecting its deficiency assessment of North Ridge Country Club’s (“the Club”) taxable income for 1979. A social club such as the Club is taxed on non-member income. I.R.C. §§ 501(c)(7), 512(a)(3). 1 The Club’s income from a non-member activity exceeded the direct costs of conducting the activity, but the Club reported a tax loss after considering indirect costs such as overhead. The tax court concluded that the loss was properly deductible under section 512(a)(3)(A) of the Tax…
2Cases cited7 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- The Brook, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Anaheim Union Water Company v. Commissioner of Internal Revenue, Santa Ana River Development Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Portland Golf Club v. CommissionerSupreme Court of the United States · 1990
- Simon v. Comm'rUnited States Tax Court · 1994
- 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
- Han v. CommissionerUnited States Tax Court · 1993
4 more not listed; retrieve them via the Exa API.