Exhibit 418

Bob Jones University v. United States, 461 U.S. 574

Exhibit 418 · Court opinion

Bob Jones University v. United States, 461 U.S. 574

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.

Held that a school with racially discriminatory policies, including one based on religious belief, did not qualify as charitable under §501(c)(3), and that denial of the exemption did not violate the Religion Clauses because of the government interest in eradicating racial discrimination in education. Chief Justice Burger for the Court; Justice Rehnquist dissented. The opinion states the general rationale for charitable exemption.

Source: Supreme Court of the United States
Date: 24 May 1983
Quoted from: 461 U.S. 574, 591 (Part II-A; pages 585-592 per syllabus)
Grade: Primary record
Document: https://tile.loc.gov/storage-services/service/ll/usrep/usrep461/usrep461574/usrep461574.pdf
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Cited by

Finding REL-4.2: Primary record The Church Audit Procedures Act of 1984 (26 U.S.C. § 7611) permits the IRS to begin a church tax inquiry only on a written reasonable belief held by an appropriate high-level Treasury official and written notice to the church, and requires written approval of regional counsel before a revocation, deficiency notice or assessment. Congress enacted it after a 1983 Senate hearing at which the chairman cited constitutional entanglement and the harm of extended examinations to small congregations.