International E22 Class Association v. Commissioner

78 T.C. 93 (1982)

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International E22 Class Association v. Commissioner

United States Tax Court
78 T.C. 93 (1982)

Facts

International E22 Class Association (the association) (plaintiff) was organized to maintain the one-design character of the international E22 yacht and to promote and coordinate national and international competition in the E22 sailing class. The association accomplished these purposes by monitoring the building of E22 sailboats to ensure compliance with specifications; formulating and enforcing rules pertaining to the size, shape, and design of the boats; arranging races for E22 sailboats; and publishing information about E22-class racing. The association owned a master plug and measurement templates that it made available, free of charge, to licensed builders. The master plug was a precisely measured, full-size, fiberglass version of the hull of an E22-class sailboat. Licensed builders were permitted to use the master plug to make molds for the construction of boats that would thus conform to the design specifications for that class of racing. Likewise, the measurement templates were precisely measured models of various parts of an E22-class sailboat, including the rudder, keel, mast, and boom. The commissioner of internal revenue (commissioner) (defendant) denied the association’s application for exemption under § 501(c)(3) of the Internal Revenue Code, and the association challenged the adverse determination.

Rule of Law

Issue

Holding and Reasoning (Wilbur, J.)

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