Variety Club Tent No. 6 Charities, Inc. - Page 25

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          812(d)), while the term “private shareholder or individual”                 
          appears in paragraph (4) of the same section 2055(a).  We have              
          not found any explanation of the intended difference between                
          “stockholder” and “shareholder”, nor any reason why “stockholder”           
          was replaced by “shareholder” in the Revenue Act of 1924.  See              
          Western Natl. Mut. Ins. Co. v. Commissioner, 102 T.C. 338, 354              
          (1994), affd. 65 F.3d 90 (8th Cir. 1995).                                   
               Section 1.501(a)-1(c), Income Tax Regs., provides as                   
          follows:                                                                    
                    (c) “Private shareholder or individual” defined.  The             
               words “private shareholder or individual” in section 501               
               refer to persons having a personal and private interest in             
               the activities of the organization.                                    
          This definition is unchanged from Regs. 65, art. 517 (1924),                
          except that the older regulations use “individuals” and                     
          “corporation”, instead of “persons” and “organization”,                     
          respectively.  Art. 517 of Regs. 65 is essentially similar to               
          Regs. 45, art. 517 (1920).  In general, the case law appears to             
          have drawn a line between those who have significant control over           
          the organization’s activities and those who are unrelated third             
          parties.  United Cancer Council, Inc. v. Commissioner, 109 T.C.             
          __, __ (1997) (slip op. at 91); People of God Community v.                  
          Commissioner, 75 T.C. 127, 133 (1980).                                      
               (1) Zeve                                                               
               Zeve, a former president of petitioner, was petitioner’s               
          treasurer during the years in issue.  As treasurer, he was a                





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