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Whatever may be the rationale for such private schools' policies, racial discrimination in education is contrary to public policy. (c) The IRS did not exceed its authority when it announced its interpretation of § 501(c)(3) in 19. J., delivered the opinion of the Court, in which BRENNAN, WHITE, MARSHALL, BLACKMUN, STEVENS, and O'CONNOR, JJ., joined, and in Part III of which POWELL, J., joined. The court permanently enjoined the Commissioner of [p579] 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"]. Its purpose is "to conduct an institution [p580] of learning . 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. Entering students are screened as to their religious beliefs, and their public and private conduct is strictly regulated by standards promulgated by University authorities. 1127 (DC 1970), the IRS formally notified the University of the change in IRS policy, and announced its intention to challenge the tax-exempt status of private schools practicing racial discrimination in their admissions policies. 725 (1974), in which this Court held that the Anti-Injunction Act of the Internal Revenue Code, 26 U. Thereafter, on April 16, 1975, the IRS notified the University of the proposed revocation of its tax-exempt status. housing and related facilities from which Americans are excluded because of their race, color, creed, or national origin is unfair, unjust, and inconsistent with the public policy of [p595] the United States as manifested in its Constitution and laws. In § 170 and § 501(c)(3), Congress has identified categories of traditionally exempt institutions and has specified certain additional requirements for tax exemption. 517(1) (1921), for example, the IRS's predecessor denied charitable exemptions on the basis of proscribed political activity before the Congress itself added such conduct as a disqualifying element. On the record before us, there can be no doubt as to the national policy. Clearly an educational institution engaging in [p599] practices affirmatively at odds with this declared position of the whole Government cannot be seen as exercising a "beneficial and stabilizing influenc[e] in community life," 397 U. at 673, and is not "charitable," within the meaning of § 170 and § 501(c)(3). Petitioner Goldsboro Christian Schools admits that it "maintain[s] racially discriminatory policies," Brief for Petitioner in No. 10, but seeks to justify those policies on grounds we have fully discussed. For example, the Bogerts state: In return for the favorable treatment accorded charitable gifts which imply some disadvantage to the community, the courts must find in the trust which is to be deemed "charitable" some real advantages to the public which more than offset the disadvantages arising out of special privileges accorded charitable trusts.

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, TOP Opinion BURGER, C. Thereafter, in July, 1970, the IRS concluded that it could "no longer legally justify allowing tax-exempt status [under § 501(c)(3)] to private schools which practice racial discrimination." IRS News Release, July 7, 1970, reprinted in App. 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, . The sponsors of the University genuinely believe that the Bible forbids interracial dating and marriage. The University continues to deny admission to applicants engaged in an interracial marriage or known to advocate interracial marriage or dating. After failing to obtain an assurance of tax exemption through administrative means, the University instituted an action in 1971 seeking to enjoin the IRS from revoking the school's tax-exempt status. On January 19, 1976, the IRS officially revoked the University's tax-exempt status, effective as of December 1, 1970, the day after the University was formally notified of the change in IRS policy. And in 1962, President Kennedy announced: [T]he granting of Federal assistance for . Yet the need for continuing interpretation of those statutes is unavoidable. In other instances, the IRS has denied charitable exemptions to otherwise qualified entities because they served too limited a class of people, and thus did not provide a truly "public" benefit under the common law test. In 1970, when the IRS first issued the ruling challenged here, the position of all three branches of the Federal Government was unmistakably clear. We therefore hold that the IRS did not exceed its authority when it announced its interpretation of § 170 and § 501(c)(3) in 19. That provision denies tax-exempt status to social clubs whose charters or policy statements provide for "discrimination against any person on the basis of race, color, or religion." Both the House and Senate Committee Reports on that bill articulated the national policy against granting tax exemptions to racially discriminatory private clubs. The IRS properly denied tax-exempt status to Goldsboro Christian Schools.

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, 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 4 A. What little floor debate occurred on the charitable exemption provision of the 1894 Act and similar sections of later statutes leaves no doubt that Congress deemed the specified organizations entitled to tax benefits because they served desirable public purposes. In floor debate on a similar provision in 1917, for example, Senator Hollis articulated the rationale: For every dollar that a man contributes for these public charities, educational, scientific, or otherwise, the public gets 100 per cent.

That court found an "identity for present purposes" between the and we affirm in each. organized and operated exclusively for religious, charitable . Petitioners argue that the plain language of the statute guarantees them tax-exempt status. 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.

II A 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. 447, Congress expressly reconfirmed this view with respect to the charitable deduction provision: 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. B 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. Congress, in Titles IV and VI of the Civil Rights Act of 1964, Pub.

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. 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. It is both a religious and educational institution. These are but a few of numerous Executive Orders over the past three decades demonstrating the commitment of the Executive Branch to the fundamental policy of eliminating racial discrimination. In an area as complex as the tax system, the agency Congress vests with administrative responsibility must be able to exercise its authority to meet changing conditions and new problems. Since Congress cannot be expected to anticipate every conceivable problem that can arise or to carry out day-to-day oversight, it relies on the administrators and on the courts to implement the legislative will. This in turn may necessitate later determinations of whether given activities so violate public policy that the entities involved cannot be deemed to provide a public benefit worthy of "charitable" status. Bull., at 231, is wholly consistent with what Congress, the Executive, and the courts had repeatedly declared before 1970. That governmental interest substantially outweighs whatever burden denial of tax benefits places on petitioners' exercise of their religious beliefs. JUSTICE POWELL concedes that, if any national policy is sufficiently fundamental to constitute such an overriding limitation on the availability of tax-exempt status under § 501(c)(3), it is the policy against racial discrimination in education. Since that policy is sufficiently clear to warrant JUSTICE POWELL's concession and for him to support our finding of longstanding congressional acquiescence, it should be apparent that his concerns about the Court's opinion are unfounded. In light of our resolution of this litigation, we do not reach that issue.

The District Court entered summary judgment for [p575] 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. 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. At the same time, the IRS announced that it could not "treat gifts to such schools as charitable deductions for income tax purposes [under § 170]." By letter dated November 30, 1970, the IRS formally notified private schools, including those involved in this litigation, of this change in policy, "applicable to all private schools in the United States at all levels of education." 404 U. 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. 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. Its teachers are required to be devout Christians, and all courses at the University are taught according to the Bible. § 7421(a), prohibited the University from obtaining judicial review by way of injunctive action before the assessment or collection of any tax. Indeed, as early as 1918, Congress expressly authorized the Commissioner "to make all needful rules and regulations for the enforcement" of the tax laws. Administrators, like judges, are under oath to do so. Some years before the issuance of the rulings challenged in these cases, the IRS also ruled that contributions to community recreational facilities would not be deductible, and that the facilities themselves would not be entitled to tax-exempt status, unless those facilities were open to all on a racially nondiscriminatory basis. We emphasize, however, that these sensitive determinations should be made only where there is no doubt that the organization's activities violate fundamental public policy. Indeed, it would be anomalous for the Executive, Legislative, and Judicial Branches to reach conclusions that add up to a firm public policy on racial discrimination, and at the same time have the IRS blissfully ignore what all three branches of the Federal Government had declared. The interests asserted by petitioners cannot be accommodated with that compelling governmental interest, [p605] IV The remaining issue is whether the IRS properly applied its policy to these petitioners. The common law requirement of public benefit is universally recognized by commentators on the law of trusts.

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