The bob jones policy on interracial dating
The Government counterclaimed for unpaid federal unemployment taxes for the taxable years 1971 through 1975, in the amount of 9,675.59, plus interest. The Court of Appeals for the Fourth Circuit, in a divided opinion, reversed. The court held that the IRS acted within its statutory authority in revoking the University's tax-exempt status. United States Goldsboro Christian Schools is a nonprofit corporation located in Goldsboro, N. Like Bob Jones University, it was established "to conduct an institution or institutions of learning . ., giving special emphasis to the Christian religion and the ethics revealed in the Holy scriptures." Articles of Incorporation § 3(a); see Complaint § 6, reprinted in App. Since its incorporation in 1963, Goldsboro Christian Schools has maintained a racially discriminatory admissions policy based upon its interpretation of the Bible. After its request for a refund was denied, the University instituted the present action, seeking to recover the it had paid to the IRS. The court accordingly ordered the IRS to pay the University the refund it claimed and rejected the IRS's counterclaim. In the court's view, Bob Jones University did not meet this requirement, since its "racial policies violated the clearly defined public policy, rooted in our Constitution, condemning racial discrimination and, more specifically, the government policy against subsidizing racial discrimination in education, public or private." 639 F.2d, at 151. The school requires its high school students to take Bible-related courses, and begins each class with prayer. After paying a portion of such taxes for certain years, Goldsboro filed a refund suit in Federal District Court, and the IRS counterclaimed for unpaid taxes. (a) An examination of the IRC's framework and the background of congressional purposes reveals unmistakable evidence that underlying all relevant parts of the IRC is the intent that entitlement to tax exemption depends on meeting certain common-law standards of charity - namely, that an institution seeking tax-exempt status must serve a public purpose and not be contrary to established public policy. (b) The IRS's 1970 interpretation of 501(c)(3) was correct. The District Court entered summary judgment for 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. Held: 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. Because of this admissions policy, the IRS revoked the University's tax-exempt status.
Goldstein for the National Association for the Advancement of Colored People et al.; by Leon Silverman, Linda R. Mansfield for the National Association of Independent Schools; by Charles E. Goldsboro never received a determination by the IRS that it was an organization entitled to tax exemption under 501(c)(3). In 1891, in a restatement of the English law of charity 13 which has long been recognized as a leading authority in this country, Lord Mac Naghten stated: "`Charity' in its legal sense comprises four principal divisions: trusts for the relief of poverty; trusts for the advancement of education; trusts for the advancement of religion; and trusts for other purposes beneficial to the community, not falling under any of the preceding heads." Commissioners v. 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. 3 The application of the IRS construction of these provisions to petitioners, two private schools with racially discriminatory admissions policies, is now before us. Entering students are screened as to their religious beliefs, and their public and private conduct is strictly regulated by standards promulgated by University authorities. 15 "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." H. 18 History buttresses logic to make clear that, 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. That court approved the IRS's amended construction of the Tax Code. All charitable trusts, educational or otherwise, are subject to the requirement that the purpose of the trust may not be illegal or contrary to public policy." 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." Id., at 231. ., giving special emphasis to the Christian religion and the ethics revealed in the Holy Scriptures." Certificate of Incorporation, Bob Jones University, Inc., of Greenville, S. Its teachers are required to be devout Christians, and all courses at the University are taught according to the Bible. 17 When the Government grants exemptions or allows deductions all taxpayers are affected; the very fact of the exemption or deduction for the donor means that other taxpayers can be said to be indirect and vicarious "donors." Charitable exemptions are justified on the basis that the exempt entity confers a public benefit - a benefit which the society or the community may not itself choose or be able to provide, or which supplements and advances the work of public institutions already supported by tax revenues. The origins of such exemptions lie in the special privileges that have long been extended to charitable trusts. And it is well settled that, in interpreting a statute, the court will not look merely to a particular clause in which general words may be used, but will take in connection with it the whole statute . Tax exemptions for certain institutions thought beneficial to the social order of the country as a whole, or to a particular community, are deeply rooted in our history, as in that of England.