St. Louis Science Fiction Limited v. Commissioner

St. Louis Science Fiction Limited (Sci-Fi) (plaintiff) was organized to promote the reading, writing, viewing, and appreciation of the science-fiction and fantasy genres. Sci-Fi’s principal activity was conducting an annual convention in St. Louis. The convention was widely advertised and open to the public. Activities at the 1980 convention included a masquerade party, a pool party, a 24-hour video room, and a 24-hour gaming room. The 1981 convention offered expanded gaming facilities hosting multiple tournaments, a large movie room with two video screens, and a 24-hour hospitality room. Films shown included science-fiction classics like 2001: A Space Odyssey, but most were lighter fare, such as Hardware Wars, a spoof on Star Wars. The conventions also included panel discussions. Again, some involved serious literary or critical topics, but most were recreational in nature. In addition, science-fiction and fantasy artwork were auctioned at the conventions, with Sci-Fi retaining a 15 percent commission on sales. Huckster’s tables, where attendees could sell books and other items, were also available to rent. The commissioner of internal revenue (commissioner) (defendant) denied Sci-Fi’s application for exemption from income taxation, finding that Sci-Fi was operated in furtherance of substantial nonexempt commercial, social, and entertainment purposes. Sci-Fi sought a declaratory judgment to the effect that it was entitled to § 501(c)(3) exemption.