Columbia Park & Recreation Asso. v. Commissioner
United States Tax Court
P is a sec. 501(c)(4), I.R.C. 1954, organization exempt from tax under sec. 501(a), I.R.C. 1954. P sought to be qualified as a charitable organization under sec. 501(c)(3), I.R.C. 1954, to, among other things, be able to obtain the benefit of sec. 103, I.R.C. 1954, bond financing.
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P is a sec. 501(c)(4), I.R.C. 1954, organization exempt from tax under sec. 501(a), I.R.C. 1954. P sought to be qualified as a charitable organization under sec. 501(c)(3), I.R.C. 1954, to, among other things, be able to obtain the benefit of sec. 103, I.R.C. 1954, bond financing. R issued an adverse ruling determining that P was not organized or operated exclusively for an exempt purpose within the meaning of sec. 501(c)(3), I.R.C. 1954. P seeks a declaratory judgment from R's adverse ruling. C is a private real estate development with a population of more than 100,000 residents. It is a…
1Opinion of the Court
Columbia Park and Recreation Association, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Columbia Park & Recreation Asso. v. Commissioner
Docket No. 19537-84X
United States Tax Court
88 T.C. 1; 1987 U.S. Tax Ct. LEXIS 1; 88 T.C. No. 1;
January 6, 1987. January 6, 1987, Filed
P is a sec. 501(c)(4), I.R.C. 1954, organization exempt from tax under sec. 501(a), I.R.C. 1954. P sought to be qualified as a charitable organization under sec. 501(c)(3), I.R.C. 1954, to, among other things, be able to obtain the benefit of sec. 103, I.R.C. 1954, bond financing. R issued an adverse ruling…
2Cases cited36 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burnet v. HarmelSupreme Court of the United States · 1932
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- New York v. MacLaySupreme Court of the United States · 1933
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