Presbyterian and Reformed Publishing Co. v. Commissioner
United States Court of Appeals for the Third Circuit
743 F.2d 148 (1984)
- Written by Sean Carroll, JD
Facts
Presbyterian and Reformed Publishing Company (P&R) (plaintiff) was a nonprofit organization formed to disseminate the teachings of the Orthodox Presbyterian Church (OPC). P&R had no formal affiliation with the OPC. In 1939, P&R obtained tax-exempt status from the Internal Revenue Service (IRS) (defendant). P&R did not earn a profit until 1969, when one of its books became popular. Over the subsequent years, P&R amassed significant revenues. P&R established a building fund and ultimately bought property and built a warehouse and offices. In 1980, the IRS revoked P&R’s tax-exempt status. P&R appealed the decision in the United States Tax Court. The tax court affirmed the revocation. P&R appealed.
Rule of Law
Issue
Holding and Reasoning (Adams, J.)
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