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United States Fourth Circuit


Ocean Pines Ass'n, Inc. v. Comm'r of Internal Revenue, 11-1029

On petition for a redetermination of federal income tax deficiencies brought by a 501(c)(4) nonprofit homeowners association, the Tax Court's ruling against the association is affirmed, where the net income derived by the association from its parking lots and beach club benefitted the private interests of the association members rather than the general public, and therefore was not "substantially related" to the association's purpose of promoting social welfare, but rather was taxable as "unrelated business taxable income" under IRC sections 511-513.

Appellate Information

  • Decided 03/02/2012
  • Published 03/02/2012

Judges

  • Diana Gribbon Motz

Court

  • United States Fourth Circuit

Counsel

  • For Appellant:
  • Jerrold A. Thrope, Teresa Thomas Milton

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