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. 3 The application of the IRS construction of these provisions to petitioners, two private schools with racially discriminatory admissions policies, is now before us. Entering students are screened as to their religious beliefs, and their public and private conduct is strictly regulated by standards promulgated by University authorities. 15 "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." H. 18 History buttresses logic to make clear that, 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. 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." 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." Id., at 231. ., 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. Its teachers are required to be devout Christians, and all courses at the University are taught according to the Bible. 17 When the Government grants exemptions or allows deductions all taxpayers are affected; the very fact of the exemption or deduction for the donor means that other taxpayers can be said to be indirect and vicarious "donors." Charitable exemptions are justified on the basis that the exempt entity confers a public benefit - a benefit which the society or the community may not itself choose or be able to provide, or which supplements and advances the work of public institutions already supported by tax revenues. 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]." Ibid. Following the decision of the United States Court of Appeals for the Fourth Circuit in Mc Crary v. Since May 29, 1975, the University has permitted unmarried Negroes to enroll; but a disciplinary rule prohibits interracial dating and marriage. 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. 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. Prior to 1954, public education in many places still was conducted under the pall of Plessy v. From 1971 to May 1975, the University accepted no applications from unmarried Negroes, 5 but did accept applications from Negroes married within their race. 160 (1976), prohibiting racial exclusion from private schools, the University revised its policy. 7421(a), prohibited the University from obtaining judicial review by way of injunctive action before the assessment or collection of any tax. These statements clearly reveal the legal background against which Congress enacted the first charitable exemption statute in 1894: 14 charities were to be given preferential treatment because they provide a benefit to society. But there can no longer be any doubt that racial discrimination in education violates deeply and widely accepted views of elementary justice. 537 (1896); racial segregation in primary and secondary education prevailed in many parts of the country. g., Segregation and the Fourteenth Amendment in the States (B. 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.
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. 6 Goldsboro has for the most part accepted only Caucasians.
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.
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.
Montgomery for the National Association of Evangelicals; and by Congressman Trent Lott, pro se. Inman for the International Human Rights Law Group; by Robert H. The Court of Appeals for the Fourth Circuit affirmed, 644 F.2d 879 (1981) (per curiam). organized and operated exclusively for religious, charitable . Petitioners argue that the plain language of the statute guarantees them tax-exempt status. This "charitable" concept appears explicitly in 170 of the Code.