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Goldsboro never received a determination by the IRS that it was an organization entitled to tax exemption under § 501(c)(3). It is also suggested that § 170 is "at best of little usefulness in finding the meaning of § 501(c)(3)," since "§ 170(c) simply tracks the requirements set forth in § 501(c)(3)," at 614.
Upon audit of Goldsboro's records for the years 1969 through 1972, the IRS determined that Goldsboro was not an organization described in § 501(c)(3), and therefore was required to pay taxes under the Federal Insurance Contribution Act and the Federal Unemployment Tax Act. That reading loses sight of the fact that § 170(c) defines the term "charitable contribution." The plain language of § 170 reveals that Congress' objective was to employ tax exemptions and deductions to promote certain purposes. 487, stated that the § 501(c)(3) exemption was available only to institutions that served "the specified charitable purposes," H.
An important Bible verse about understanding interracial marriage is 2 Corinthians : "Do not be unequally yoked with unbelievers." That last word, "unbelievers" is of key importance.
A Christian should not marry a non-Christian no matter how kind and good they are. Deuteronomy 7:1-6 tells the Israelites to destroy all the inhabitants of the Canaan land and not to intermarry with them because they would "turn your sons away from following Me, that they may serve other gods." The same key concern of 2 Corinthians is again expressed here.
[p584] Goldsboro paid the IRS ,459.93 in withholding, social security, and unemployment taxes with respect to one employee for the years 1969 through 1972. In addressing the motions for summary judgment, the court assumed that Goldsboro's racially discriminatory admissions policy was based upon a sincerely held religious belief. While the eight categories of institutions specified in the statute are indeed presumptively charitable in nature, the IRS properly considered principles of charitable trust law in determining whether the institutions in question may truly be considered "charitable" for purposes of entitlement to the tax benefits conferred by § 170 and § 501(c)(3). The House Report on the Tax Reform Act of 1969, Pub.
Thereafter, Goldsboro filed a suit seeking refund of that payment, claiming that the school had been improperly denied § 501(c)(3) exempt status. The court nevertheless rejected Goldsboro's claim to tax-exempt status under § 501(c) (3), finding that private schools maintaining racially discriminatory admissions policies violate clearly declared federal policy, and therefore must be denied the federal tax benefits flowing from qualification under Section 501(c)(3). The court also rejected Goldsboro's arguments that denial of tax-exempt status violated the Free Exercise and Establishment Clauses of the First Amendment. [p591] A corollary to the public benefit principle is the requirement, long recognized in the law of trusts, that the purpose of a charitable trust may not be illegal or violate established public policy. §§ 2000c 2000c-6, 2000d, clearly expressed its agreement that racial discrimination in education violates a fundamental public policy. The form and history of the charitable exemption and deduction sections of the various income tax Acts reveal that Congress was guided by the common law of charitable trusts.
Goldsboro has for the most part accepted only Caucasians. [p600] Ordinarily, and quite appropriately, courts are slow to attribute significance to the failure of Congress to act on particular legislation. Exhaustive hearings have been held on the issue at various times since then. Not one of these bills has emerged from any committee, although Congress has enacted numerous other amendments to § 501 during this same period, including an amendment to § 501(c)(3) itself. The Government suggested that these actions were therefore moot. The Government continues to assert that the IRS lacked authority to promulgate Revenue Ruling 71-447, and does not defend that aspect of the rulings below. 509, Liles & Blum, Development of the Federal Tax Treatment of Charities, 39 Law & Contemp. This assertion dissolves when one sees that § 501(c)(3) and § 170 are construed together, as they must be. We need not consider whether Congress intended to incorporate into the Internal Revenue Code any aspects of charitable trust law other than the requirements of public benefit and a valid public purpose. 601 (1895), for reasons unrelated to the charitable exemption provision. A similar exemption has been included in every income tax Act since the adoption of the Sixteenth Amendment, beginning with the Revenue Act of 1913, ch.
On occasion, however, the school has accepted children from racially mixed marriages in which one of the parents is Caucasian. 30, 1979; replaced by similar provisions in the Emergency School Aid Act of 1978, Pub. Before this Court ruled on that motion, however, the United States Court of Appeals for the District of Columbia Circuit enjoined the Government from granting § 501(c)(3) tax-exempt status to any school that discriminates on the basis of race. The predecessor of § 170 originally was enacted in 1917, as part of the War Revenue Act of 1917, ch. 330, whereas the predecessor of 501(c)(3) dates back to the income tax law of 1894, Act of Aug. The dissent acknowledges that the two sections are "mirror" provisions; surely there can be no doubt that the Court properly looks to § 170 to determine the meaning of § 501(c)(3). The draftsmen of the 1894 income tax law, which included the first charitable exemption provision, relied heavily on English concepts of taxation, and the list of exempt organizations appears to have been patterned upon English income tax statutes. The terms of that exemption were, in substance, included in the corporate income tax contained in the Payne-Aldrich Tariff Act of 1909, ch.
The District Court entered summary judgment for [p575] the IRS, rejecting Goldsboro's claim to tax-exempt status under § 501(c) (3) and also its claim that the denial of such status violated the Religion Clauses of the First Amendment. Neither petitioner qualifies as a tax-exempt organization under § 501(c)(3). Thus, to warrant exemption under § 501(c)(3), an institution must fall within a category specified in that section, and must demonstrably serve and be in harmony with the public interest, and the institution's purpose must not be so at odds with the common community conscience as to undermine any public benefit that might otherwise be conferred. It would be wholly incompatible with the concepts underlying tax exemption to grant tax-exempt status to racially discriminatory private educational entities. At the same time, the IRS announced that it could not "treat gifts to such schools as charitable deductions for income tax purposes [under § 170]." By letter dated November 30, 1970, the IRS formally notified private schools, including those involved in this litigation, of this change in policy, "applicable to all private schools in the United States at all levels of education." 404 U. The court also held that racially discriminatory private schools were not entitled to exemption under § 501(c)(3) and that donors were not entitled to deductions for contributions to such schools under § 170. Based on the "national policy to discourage racial discrimination in education," the IRS ruled that a [private] school not having a racially nondiscriminatory policy as to students is not 'charitable' within the common law concepts reflected in sections 170 and 501(c)(3) of the Code. Its teachers are required to be devout Christians, and all courses at the University are taught according to the Bible. § 7421(a), prohibited the University from obtaining judicial review by way of injunctive action before the assessment or collection of any tax. Indeed, as early as 1918, Congress expressly authorized the Commissioner "to make all needful rules and regulations for the enforcement" of the tax laws. Administrators, like judges, are under oath to do so. Some years before the issuance of the rulings challenged in these cases, the IRS also ruled that contributions to community recreational facilities would not be deductible, and that the facilities themselves would not be entitled to tax-exempt status, unless those facilities were open to all on a racially nondiscriminatory basis. We emphasize, however, that these sensitive determinations should be made only where there is no doubt that the organization's activities violate fundamental public policy. Indeed, it would be anomalous for the Executive, Legislative, and Judicial Branches to reach conclusions that add up to a firm public policy on racial discrimination, and at the same time have the IRS blissfully ignore what all three branches of the Federal Government had declared. The interests asserted by petitioners cannot be accommodated with that compelling governmental interest, [p605] IV The remaining issue is whether the IRS properly applied its policy to these petitioners. The common law requirement of public benefit is universally recognized by commentators on the law of trusts.
Under that view, to qualify for a tax exemption pursuant to § 501(c)(3), an institution must show, first, that it falls within one of the eight categories expressly set forth in that section, and second, that its activity is not contrary to settled public policy. Instead, they argue that, if an institution falls within one or more of [p586] the specified categories it is automatically entitled to exemption, without regard to whether it also qualifies as "charitable." The Court of Appeals rejected that contention and concluded that petitioners' interpretation of the statute "tears section 501(c)(3) from its roots." 639 F.2d at 151. , taken by themselves, and literally construed, without regard to the object in view, would seem to sanction the claim of the plaintiff. In 1924, this Court restated the common understanding of the charitable exemption provision: Evidently, the exemption is made in recognition of the benefit which the public derives from corporate activities of the class named, and is intended to aid them when not conducted for private gain. But there can no longer be any doubt that racial discrimination in education violates deeply and widely accepted views of elementary justice. Over the past quarter of a century, every pronouncement of this Court and myriad Acts of Congress and Executive Orders attest a firm national policy to prohibit racial segregation and discrimination in public education.
It is a well-established canon of statutory construction that a court should go beyond the literal language of a statute if reliance on that language would defeat the plain purpose of the statute: The general words used in the clause . But this mode of expounding a statute has never been adopted by any enlightened tribunal -- because it is evident that, in many cases, it would defeat the object which the Legislature intended to accomplish. Prior to 1954, public education in many places still was conducted under the pall of [p593] 347 U. An unbroken line of cases following establishes beyond doubt this Court's view that racial discrimination in education violates a most fundamental national public policy, as well as rights of individuals. is indeed so fundamental and pervasive that it is embraced in the concept of due process of law.
That court found an "identity for present purposes" between the and we affirm in each. organized and operated exclusively for religious, charitable . Petitioners argue that the plain language of the statute guarantees them tax-exempt status. The institution's purpose must not be so at odds with the common community conscience as to undermine any public benefit that might otherwise be conferred.
II A In Revenue Ruling 71-447, the IRS formalized the policy, first announced in 1970, that § 170 and § 501(c)(3) embrace the common law "charity" concept. They emphasize the absence of any language in the statute expressly requiring all exempt organizations to be "charitable" in the common law sense, and they contend that the disjunctive "or" separating the categories in § 501(c)(3) precludes such a reading. 447, Congress expressly reconfirmed this view with respect to the charitable deduction provision: The exemption from taxation of money or property devoted to charitable and other purposes is based upon the theory that the Government is compensated for the loss of revenue by its relief from financial burdens which would otherwise have to be met by appropriations from other public funds, and by the benefits resulting from the promotion of the general welfare. B We are bound to approach these questions with full awareness that determinations of public benefit and public policy are sensitive matters with serious implications for the institutions affected; a declaration that a given institution is not "charitable" should be made only where there can be no doubt that the activity involved is contrary to a fundamental public policy. Congress, in Titles IV and VI of the Civil Rights Act of 1964, Pub.