Texas Trade School v. Commissioner of Internal Revenue
TEXAS TRADE SCHOOL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Opinion
PER CURIAM.
The Commissioner of Internal Revenue determined that Texas Trade School, petitioner, was not entitled to exemption from taxation under Section 101(6) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 101 (6). This section exempts from taxation corporations organized and operated exclusively for educational purposes, no part of the net earnings of which inures to the benefit of any prior shareholder or individual. The basis for this determination was that five individuals, four of whom were members of the executive committee of the School and all of whom were members of the Board of Directors shared in petitioner’s net earnings as a result of the payment to them of excessive and unreasonable rent for real estate leased to the petitioner and as the result of the construction by petitioner of buildings which became part of their real estate. The Tax Court carefully reviewed the facts and the law and upheld the determination of the Commissioner. 30 T.C. 642 . We find that the record fully supports the holding of the Tax Court and we adopt the opinion of the Tax Court as the opinion of this Court.
The judgment of the Tax Court is Affirmed.
How later courts describe this case
No later court has written an explanatory parenthetical about this case yet.
Cited by 12 cases
View all citing references →Relies on it most ⓘ
- Hancock Academy of Savannah, Inc. v. Commissioner
- The Founding Church of Scientology v. The United States
- Knollwood Memorial Gardens v. Commissioner
- Cleveland Chiropractic College, a Corporation v. Commissioner of Internal Revenue
- Rose Hill Memorial Park, Inc. v. Commissioner
- Washington Park Cemetery Asso. v. Commissioner
Citing references are not a citator: they show that a later opinion cites this case, not whether it followed, distinguished, or overruled it. Check negative history before relying on this case.