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activities advertising Amendment applied assets Association attorney Bob Jones University charitable organizations charitable purposes charitable trust Church clubs College Commissioner Congress constitutional contributions deduction directors disqualified person distribution donations donors educational excise tax exempt organizations exempt purposes exempt status expenditures expenses fees fiduciary for-profit foundation's fundraising funds gift grants gross hospital individual institutions interest Internal Revenue Code Internal Revenue Service inurement investment income issue legislation limited lobbying Mary Sue Hubbard membership ment nonprofit corporation nonprofit organizations nonprofit sector organiza organization's percent petitioner petitioner's Philanthropy plaintiffs private foundation profit public benefit public benefit corporations public charities qualify received regulations religious REVENUE RULING Ron Hubbard rule S.Ct schools self-dealing social substantial supporting organization Supreme Court Tax Court tax exemption tax-exempt status taxation taxpayer tion trade or business transactions Treas UBIT United