Airlie Foundation v. Internal Revenue Service

283 F. Supp. 2d 58 (2003)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Airlie Foundation v. Internal Revenue Service

United States District Court for the District of Columbia
283 F. Supp. 2d 58 (2003)

Facts

Airlie Foundation (foundation) (plaintiff) was recognized by the United States Internal Revenue Service (IRS) (defendant) as a tax-exempt organization beginning in 1963. The foundation was organized for educational purposes, and its primary operations involved organizing, hosting, and sponsoring educational conferences at a conference facility the foundation owned. The conferences were focused on a diverse range of topics, including civil and human rights, international relations, the environment, and medical education. The foundation also sponsored events, such as lectures, concerts, and art shows, and provided meeting space for nonprofit entities. Most of the foundation’s conference patrons were exempt organizations, but 30 to 40 percent were not, as the foundation hosted weddings and other special events and competed with both commercial and noncommercial enterprises for that business. The foundation also maintained a commercial website and paid significant advertising and promotional expenses. The foundation hosted an average of 600 events per year and derived about 85 percent of its operating revenue from fees paid by clients. The IRS requested a list of patrons who had used the foundation’s facilities in 1999. Data the foundation furnished in response showed that approximately 17 percent of the 651 events hosted that year were provided for fees covering less than the foundation’s total costs. The IRS found that the foundation had operated its conference center for a nonexempt, commercial purpose and revoked the foundation’s tax-exempt status. The foundation sought a declaratory judgment that it was entitled to the tax exemption, and the parties filed cross-motions for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership