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Fn Fn Briefs of amici curiae urging reversal in No. 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. 11 The form of 170 simply makes plain what common sense and history tell us: in enacting both 170 and 501(c)(3), Congress sought to provide tax benefits to charitable organizations, to encourage the development of private institutions that serve a useful public purpose or supplement or take the place of public institutions of the same kind. 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 . ., taken by themselves, and literally construed, without regard to the object in view, would seem to sanction the claim of the plaintiff. 10 In 170, Congress used the list of organizations in defining the term "charitable contributions." On its face, therefore, 170 reveals that Congress' intention was to provide tax benefits to organizations serving charitable purposes. to public charitable uses, provided the same is consistent with local laws and public policy. Richard Larson, and Samuel Rabinove for the American Civil Liberties Union et al.; by Harold P. 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 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. It is apparent that Congress intended that list to have the same meaning in both sections. Briefs of amici curiae urging affirmance in both cases were filed by Nadine Strossen, E. That court found an "identity for present purposes" between the Goldsboro case and the Bob Jones University case, which had been decided shortly 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. That section contains a list of organizations virtually identical to that contained in 501(c)(3). 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.
Assistant Attorney General Reynolds argued the cause for the United States in both cases. 12 More than a century ago, this Court announced the caveat that is critical in this case: "[I]t has now become an established principle of American law, that courts of chancery will sustain and protect .
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.
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.
United States, also on certiorari to the same court. organized and operated exclusively for religious, charitable . Until 1970, the Internal Revenue Service (IRS) granted tax-exempt status under 501(c)(3) to private schools, independent of racial admissions policies, and granted charitable deductions for contributions to such schools under 170 of the IRC.
or educational purposes" are entitled to tax exemption. With him on the briefs were Acting Solicitor General Wallace and Deputy Assistant Attorney General Cooper. Coleman, Jr., pro se, by invitation of the Court, 456 U. 922 , argued the cause as amicus curiae urging affirmance.
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.