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United Cancer Council, Inc. v. Commissioner
United States Court of Appeals for the Seventh Circuit
165 F.3d 1173 (1999)
The United Cancer Council, Inc. (UCC) (plaintiff) was a charity formed for the purpose of raising money for preventing cancer. About to go bankrupt, the UCC entered into an exclusive fundraising agreement with Watson & Hughey Company (W&H). W&H provided initial money for a fundraising campaign—essentially a loan to the UCC that the charity would pay back when it was able. Under the contract, W&H was granted coownership of the UCC’s donor list. Over the five-year contract, approximately 90 percent of the UCC’s revenue was paid to W&H for W&H’s fundraising efforts. At the end of the contract, W&H chose not to renew but rather to focus its fundraising efforts elsewhere. The Internal Revenue Service (IRS) (defendant) revoked the UCC’s status as a charity on the ground that a part of the UCC’s revenue improperly inured to the benefit of W&H. The UCC appealed the IRS’s decision in federal court. The tax court upheld the IRS’s decision, based largely on its determination that the contract between the UCC and W&H was overly favorable to W&H. The UCC appealed.
Rule of Law
Holding and Reasoning (Posner, C.J.)
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