Allgemeiner Arbeiter Verein v. Commissioner
United States Tax Court
Held, where one activity carried on by petitioner prevents it from satisfying the requirements of section 101 (9), and petitioner's other principal activity is inconsistent with section 101 (10), petitioner is not an exempt organization notwithstanding that an organization carrying on as its sole activity either of the two principal functions carried on by petitioner might qualify for an exemption under one of the two foregoing provisions.
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Held, where one activity carried on by petitioner prevents it from satisfying the requirements of section 101 (9), and petitioner's other principal activity is inconsistent with section 101 (10), petitioner is not an exempt organization notwithstanding that an organization carrying on as its sole activity either of the two principal functions carried on by petitioner might qualify for an exemption under one of the two foregoing provisions. Sec. 101, Internal Revenue Code of 1939.
1Opinion of the Court
Allgemeiner Arbeiter Verein, Petitioner, v. Commissioner of Internal Revenue, Respondent
Allgemeiner Arbeiter Verein v. Commissioner
Docket No. 51038
United States Tax Court
25 T.C. 371; 1955 U.S. Tax Ct. LEXIS 39;
November 30, 1955, Filed
Decision will be entered for the respondent.
Held, where one activity carried on by petitioner prevents it from satisfying the requirements of section 101 (9), and petitioner's other principal activity is inconsistent with section 101 (10), petitioner is not an exempt organization notwithstanding that an organization carrying on as its sole activity either of the…
2Cases cited5 opinions
- Chattanooga Automobile Club v. Commissioner of Internal Revenue. Warren Automobile Club, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
- Scofield v. Corpus Christi Golf & Country ClubCourt of Appeals for the Fifth Circuit · 1942
- Allied Trades Club, Inc. v. CommissionerUnited States Tax Court · 1955
- Allgemeiner Arbeiter Verein v. CommissionerUnited States Tax Court · 1955
- O'Reilly v. PerkinsSupreme Court of Rhode Island · 1901