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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 United States District Court for the District of South Carolina held that revocation of the University's tax-exempt status exceeded the delegated powers of the IRS, was improper under the IRS rulings and procedures, and violated the University's rights under the Religion Clauses of the First Amendment. Finally, the Court of Appeals rejected petitioner's arguments that the revocation of the tax exemption violated the Free Exercise and Establishment Clauses of the First Amendment. The school offers classes from kindergarten through high school, and, since at least 1969, has satisfied the State of North Carolina's requirements for secular education in private schools. As we noted earlier, few issues have been the subject of more vigorous and widespread debate and discussion in and out of Congress than those related to racial segregation in education. Here, however, we do not have an ordinary claim of legislative acquiescence. It is hardly conceivable that Congress -- and in this setting, any Member of Congress -- was not abundantly [p601] aware of what was going on. Section 501(c)(3) lists the following organizations, which, pursuant to § 501(a), are exempt from taxation unless denied tax exemptions under other specified sections of the Code: Corporations, and any community chest, fund, or foundation, or to foster national or international amateur sports competition (but only if no part of its activities involve the provision of athletic facilities or equipment), or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation . (Emphasis added.) Section 170(a) allows deductions for certain "charitable contributions." Section 170(c)(2)(B) includes within the definition of "charitable contribution" a contribution or gift to or for the use of a corporation "organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes. According to the interpretation espoused by Goldsboro, race is determined by descendance from one of Noah's three sons -- Ham, Shem, and Japheth. It does not ask this Court to review the rejection of that claim. 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, 19 How. Section 501(c)(3) therefore must be.analyzed and construed within the framework of the Internal Revenue Code and against the background of the congressional purposes. The right of a student not to be segregated on racial grounds in schools . Such an examination reveals unmistakable evidence that, underlying all relevant parts of the Code, 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. After paying a portion of the federal unemployment taxes for a certain taxable year, the University filed a refund action in Federal District Court, and the Government counterclaimed for unpaid taxes for that and other taxable years. 81-1, petitioner Goldsboro Christian Schools maintains a racially discriminatory admissions policy based upon its interpretation of the Bible, accepting for the most part only Caucasian students. The corporation operates a school with an enrollment of approximately 5,000 students, from kindergarten through college and graduate school. Petitioners accordingly argue that the IRS overstepped its lawful bounds in issuing its 19 rulings. Congress, the source of IRS authority, can modify IRS rulings it considers improper; and courts exercise review over IRS actions. This Court has long held the Free Exercise Clause of the First Amendment to be an absolute prohibition against governmental regulation of religious beliefs, at 402-403. The governmental interest at stake here is compelling. In the present case, the IRS issued its rulings denying exemptions to racially discriminatory schools only after a three-judge District Court had issued a preliminary injunction. JUSTICE POWELL misreads the Court's opinion when he suggests that the Court implies that the Internal Revenue Service is invested with authority to decide which public policies are sufficiently "fundamental" to require denial of tax exemptions, at 611. In setting forth the general rule, § 170 states: There shall be allowed as a deduction any charitable contribution (as defined in subsection (c)) payment of which is made within the taxable year. Holding that the IRS exceeded its powers in revoking the University's tax-exempt status and violated the University's rights under the Religion Clauses of the First Amendment, the District Court ordered the IRS to refund the taxes paid and rejected the counterclaim. The IRS determined that Goldsboro was not an organization described in § 501(c)(3), and hence was required to pay federal social security and unemployment taxes. Bob Jones University is not affiliated with any religious denomination, but is dedicated to the teaching and propagation of its fundamentalist Christian religious beliefs. Yet ever since the inception of the Tax Code, Congress has seen fit to vest in those administering the tax laws very broad authority to interpret those laws. The same provision, so essential to efficient and fair administration of the tax laws, has appeared in Tax Codes ever since, 177 U. In the first instance, however, the responsibility [p597] for construing the Code falls to the IRS. Guided, of course, by the Code, the IRS has the responsibility, in the first instance, to determine whether a particular [p598] entity is "charitable" for purposes of § 170 and § 501(c)(3). However, [n]ot all burdens on religion are unconstitutional. As discussed in Part II-B, -- discrimination that prevailed, with official approval, for the first 165 years of this Nation's constitutional history. The Court's opinion does not warrant that interpretation. (appointed by the Court), argue that denial of tax-exempt status to racially discriminatory schools is independently required by the equal protection component of the Fifth Amendment. A charitable contribution shall be allowable as a deduction only if verified [p614] under regulations prescribed by the Secretary.