Big Mama Rag v. United States
United States Court of Appeals for the District of Columbia Circuit
631 F.2d 1030 (1980)
- Written by Sean Carroll, JD
Facts
Big Mama Rag, Inc. (BMR) (plaintiff) was a nonprofit organization that sought to inform and educate women on issues important to them. BMR’s primary activity was publishing a monthly newspaper to that end. BMR also produced workshops and lectures. BMR relied mostly on charitable contributions for its expenses. BMR applied to the Internal Revenue Service (IRS) (defendant) for tax-exempt status. The IRS denied the application on the grounds that the newspaper was not educational and was indistinguishable from a regular, commercial newspaper. Under U.S. Treasury regulations promulgated pursuant to § 501(c)(3) of the Internal Revenue Code, an organization that proffered a particular viewpoint could still qualify as educational if it presented a “full and fair exposition of the pertinent facts” that enabled people to make independent decisions on the subject matter. The district court granted the IRS summary judgment, finding that BMR did not meet this standard and was not an educational or charitable organization. BMR appealed.
Rule of Law
Issue
Holding and Reasoning (Mikva, J.)
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