KJ’s Fund Raisers, Inc. v. Commissioner
United States Tax Court
T.C. Memo. 1997-424 (1997)
- Written by Daniel Clark, JD
Facts
KJ’s Place was a for-profit lounge that served alcoholic drinks. KJ’s Place’s owners, Kristine Hurd and James Gould, later founded KJ’s Fund Raisers, Inc. (Fund Raisers) (plaintiff). Fund Raisers, with the labor of KJ’s Place employees, sold scratch-off and rip lottery tickets at KJ’s Place during KJ’s Place’s regular business hours. Fund Raisers used the ticket sale proceeds to make grants to local charities. On multiple occasions, the local press featured photos, taken in front of KJ’s Place, of the charities receiving grant checks from Fund Raisers. Hurd and Gould were initially on Fund Raiser’s board of directors but formally extracted themselves from Fund Raisers’ management; however, as the owners of KJ’s Place, Hurd and Gould retained policy-making control of Fund Raisers as a practical matter. Fund Raisers petitioned the United States Tax Court for a declaratory judgment that it was entitled to tax-exempt status under § 501 of the Internal Revenue Code (code), which the Internal Revenue Service (defendant) contested.
Rule of Law
Issue
Holding and Reasoning (Raum, J.)
What to do next…
Here's why 830,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,400 briefs, keyed to 994 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.
