Hancock Academy of Savannah, Inc. v. Commissioner
United States Tax Court
Petitioner was formed as a nonprofit corporation to take over the educational functions of Hancock Schools, Inc. Petitioner assumed a liability for goodwill in an excessive amount and agreed to require parents of its students to make interest-free loans to Hancock Schools, Inc. An application for determination of qualification and exemption under sec. 501(c)(3), I.R.C. 1954, was filed with the Internal Revenue Service on petitioner's behalf.
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Petitioner was formed as a nonprofit corporation to take over the educational functions of Hancock Schools, Inc. Petitioner assumed a liability for goodwill in an excessive amount and agreed to require parents of its students to make interest-free loans to Hancock Schools, Inc. An application for determination of qualification and exemption under sec. 501(c)(3), I.R.C. 1954, was filed with the Internal Revenue Service on petitioner's behalf. The Internal Revenue Service determined that petitioner did not qualify for tax-exempt status. Thereafter petitioner filed a petition with this Court for…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(c)(3).1 Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment2 pursuant to section 7428. The issue for our decision is whether petitioner served private interests in contravention of the requirements for exempt status under section 501(c)(3).
This case was submitted for decision on the stipulated administrative record under Rule 122, Tax Court Rules of Practice and Procedure.3 The evidentiary…
2Cases cited10 opinions
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Watson v. CommissionerUnited States Tax Court · 1960
- Ohio Furnace Co. v. CommissionerUnited States Tax Court · 1955
- Estate of Howes v. CommissionerUnited States Tax Court · 1958
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3Cited by94 opinions
- Church in Boston v. CommissionerUnited States Tax Court · 1978
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- Basic Bible Church v. CommissionerUnited States Tax Court · 1980
- Western Catholic Church v. CommissionerUnited States Tax Court · 1979
- General Conference of Free Church v. CommissionerUnited States Tax Court · 1979
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