Schoger Foundation v. Commissioner

76 T.C. 380 (1981)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Schoger Foundation v. Commissioner

United States Tax Court
76 T.C. 380 (1981)

Facts

The Schoger Foundation (foundation) (plaintiff) was a nonprofit corporation whose stated purpose, according to its articles of incorporation, was to maintain and operate a religious retreat facility for the study, contemplation, and worship of God. The foundation owned a lodge in the mountains of Colorado described as a place for Christian families to rest and become reacquainted. Recreational and religious activities were available to guests, and none were scheduled or mandatory. No rate or fee was charged to guests of the lodge. Rather, the foundation solicited donations via a card placed in each unit, which stated that the average cost of a day’s lodging and meals was $20 per person and that the guest’s contribution toward these expenses would enable the ministry to continue. The foundation generated its operational funds through such contributions and other private donations. The foundation applied for exemption from federal income taxation pursuant to § 501(c)(3) of the Internal Revenue Code. The commissioner of internal revenue (commissioner) (defendant) denied the application, and the foundation sought a declaratory judgment that it was entitled to the tax exemption.

Rule of Law

Issue

Holding and Reasoning (Parker, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 802,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 802,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 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.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 802,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership