Westward Ho v. Commissioner

T.C. Memo 1992-192 (1992)

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Westward Ho v. Commissioner

United States Tax Court
T.C. Memo 1992-192 (1992)

Facts

Westward Ho (corporation) (plaintiff) was incorporated by the owners of three restaurants located in downtown Burlington, Vermont, in an area known as the Church Street Marketplace (marketplace). The incorporators’ businesses were frequently disrupted by homeless individuals who had been discharged from a nearby state mental hospital, and the incorporators expressed frustration with the problem to local authorities and through local media. The business owners formed the corporation with the intention of funding travel for disruptive or abusive individuals to leave Burlington. The corporation’s articles of association described its purpose as providing travel grants or loans to certain indigent and antisocial persons. The corporation did not have a formal method for identifying individuals who might benefit from relocation and did not accept applications for its services, nor was there any program for assistance in the new location or for determining whether relocation would help an individual. The corporation applied for tax-exempt status under § 501(c)(3) of the Internal Revenue Code, and the commissioner of internal revenue (commissioner) (defendant) denied the application. The corporation sought declaratory relief to the effect that it was entitled to the tax exemption.

Rule of Law

Issue

Holding and Reasoning (Cohen, J.)

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