Schoger Foundation v. Commissioner

76 T.C. 380 (1981)

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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.)

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