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Hutchinson Baseball Enterprises, Inc. v. Commissioner

696 F.2d 757 (1982)

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Hutchinson Baseball Enterprises, Inc. v. Commissioner

United States Court of Appeals for the Tenth Circuit

696 F.2d 757 (1982)

Facts

Hutchinson Baseball Enterprises, Inc. (Hutchinson) (plaintiff) was a nonprofit organization. Hutchinson owned and operated an amateur baseball team, the Hutchinson Broncos. The team comprised college players who were not paid for their baseball services; the players worked jobs in the Hutchinson community during the season. Hutchinson leased a field from the local municipality, Hutchinson, Kansas. Hutchinson allowed the American Legion, the local Little League, and youth baseball camps to use the field free of charge. Further, Hutchinson provided Broncos players to serve as coaches and camp counselors for these youth-baseball endeavors. Hutchinson applied for tax-exempt status with the Internal Revenue Service (IRS) (defendant). The IRS granted the application but later concluded that Hutchinson no longer qualified and revoked the status. Hutchinson appealed the ruling in the United States Tax Court. The tax court ruled in Hutchinson’s favor, finding that Hutchinson was organized for the promotion of amateur and recreational baseball. The IRS appealed.

Rule of Law

Issue

Holding and Reasoning (Holloway, J.)

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