Portland Co-Operative Labor Temple Association v. Commissioner
United States Board of Tax Appeals
39 B.T.A. 450 (1939)
- Written by Daniel Clark, JD
Facts
The Portland Co-operative Labor Temple Association (Labor Temple) (plaintiff) constructed a building in Portland, Oregon. Before the Labor Temple’s construction, local labor unions met in various venues throughout the Portland area. The Labor Temple was intended to be a home for the various local labor unions. Local unions themselves or individual members of local unions owned all the Labor Temple’s stock. The Labor Temple’s facilities included offices and meeting halls rented out to local unions. The Labor Temple also housed several social businesses, such as bars, a pool room, and a restaurant. The Labor Temple set its rental rates so as to break even rather than to make a profit. The Labor Temple’s facilities were used almost exclusively by members of local unions. The Internal Revenue Service (IRS) (defendant) and the Labor Temple went before the United States Board of Tax Appeals to litigate whether the Labor Temple qualified for exemption from federal income tax.
Rule of Law
Issue
Holding and Reasoning (Sternhagen, J.)
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