Minnesota Kingsmen Chess Association v. Commissioner

46 T.C.M. 1133 (1983)

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Minnesota Kingsmen Chess Association v. Commissioner

United States Tax Court
46 T.C.M. 1133 (1983)

Facts

The Minnesota Kingsmen Chess Association, Inc. (association) (plaintiff) was organized to promote chess as an art and as an educational competitive device that exercises and develops the brain and memory. The association organized chess tournaments that afforded club members the opportunity to compete against one another for prizes. During 1979, the association held 21 tournaments. Cash prizes derived from entry fees were awarded at 12 of those events, and members of the association won almost all the prizes. The association also donated chess magazines and books to libraries, published a quarterly newsletter, and conducted a chess class for children at a community center. Most of the newsletter content consisted of tournament results and advertisements for upcoming tournaments. In 1979, the association spent approximately 48 hours on the publication of the newsletter, 102 hours on instruction, and 96 hours on tournament activities. The commissioner of internal revenue (defendant) found that that the association did not qualify as an educational organization and denied the association’s application for exemption from income taxation under § 501(c)(3) of the Internal Revenue Code. The association sought review of the determination in the United States Tax Court.

Rule of Law

Issue

Holding and Reasoning (Dawson, C.J.)

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