Bob jones university interracial dating rules
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.
The revised policy on discrimination was formalized in Revenue Ruling 71-447, 1971-2 Cum. 230: "Both the courts and the Internal Revenue Service have long recognized that the statutory requirement of being `organized and operated exclusively for religious, charitable, . To effectuate these views, Negroes were completely excluded until 1971. 585-586 "Evidently the exemption is made in recognition of the benefit which the public derives from corporate activities of the class named, and is intended to aid them when not conducted for private gain." Trinidad v. We are bound to approach these questions with full awareness that determinations of public benefit and public policy are sensitive matters with serious implications for the institutions affected; a declaration that a given institution is not "charitable" should be made only where there can be no doubt that the activity involved is contrary to a fundamental public policy.
The court permanently enjoined the Commissioner of Internal Revenue from approving tax-exempt status for any school in Mississippi that did not publicly maintain a policy of nondiscrimination. or educational purposes' was intended to express the basic common law concept [of `charity']. The sponsors of the University genuinely believe that the Bible forbids interracial dating and marriage. 19 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.
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.
Racially discriminatory educational institutions cannot be viewed as conferring a public benefit within the above "charitable" concept or within the congressional intent underlying 501(c)(3). Such interpretation is wholly consistent with what Congress, the Executive, and the courts had previously declared. (d) The Government's fundamental, overriding interest in eradicating racial discrimination in education substantially outweighs whatever burden denial of tax benefits places on petitioners' exercise of their religious beliefs. (e) The IRS properly applied its policy to both petitioners. POWELL, J., filed an opinion concurring in part and concurring in the judgment, post, p. REHNQUIST, J., filed a dissenting opinion, post, p. Because of this admissions policy, the IRS revoked the University's tax-exempt status. Section 501(c)(3) of the Internal Revenue Code of 1954 (IRC) provides that "[c]orporations . But in 1970, the IRS concluded that it could no longer justify allowing tax-exempt status under 501(c)(3) to private schools that practiced racial discrimination, and in 1971 issued Revenue Ruling 71-447 providing that a private school not having a racially nondiscriminatory policy as to students is not "charitable" within the common-law concepts reflected in 170 and 501(c)(3). 81-3, petitioner Bob Jones University, while permitting unmarried Negroes to enroll as students, denies admission to applicants engaged in an interracial marriage or known to advocate interracial marriage or dating. William Bentley Ball argued the cause for petitioner in No. 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. Until 1970, the Internal Revenue Service granted tax-exempt status to private schools, without regard to their racial admissions policies, under 501(c)(3) of the Internal Revenue Code, 26 U. 8 The District Court for the Eastern District of North Carolina decided the action on cross-motions for summary judgment. The court also rejected Goldsboro's arguments that denial of tax-exempt status violated the Free Exercise and Establishment Clauses of the First Amendment. 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.