Bob Jones v. United States case brief

Bob Jones v. United States case brief summary
461 U.S. 574; 103 S. Ct. 2017; 76 L. Ed. 2d 157 (1983)

CASE SYNOPSIS: The Supreme Court granted certiorari to the United States Court of Appeals for the Fourth Circuit to decide whether petitioners, nonprofit private schools that prescribe and enforce racially discriminatory admissions standards on the basis of religious doctrine, qualified as tax-exempt organizations under § 501(c)(3) of the Internal Revenue Code of 1954.

CASE FACTS: 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 was not charitable within the common law concepts reflected in §§ 170 and 501(c)(3) of the Internal Revenue Code. 

DISCUSSION

• The application of the IRS construction of these provisions to petitioners, two private schools with racially discriminatory admissions policies, was affirmed, as private schools maintaining racially discriminatory admissions policies violated clearly declared federal policy and must be denied tax benefits flowing from qualification under § 501(c)(3). 
• Entitlement to tax exemption depended on meeting certain common-law standards of charity. An institution seeking tax exempt status must serve a public purpose and not be contrary to established public policy. 
• 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. 
• 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.

CONCLUSION: The court affirmed the IRS policy denying tax-exempt status to private schools with racially discriminatory admissions policies, as those policies violated clearly declared federal policy.