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And the actions of Congress since 1970 leave no doubt that the IRS reached the correct conclusion in exercising its authority. Petitioners' asserted interests cannot be accommodated with that compelling governmental interest, and no less restrictive means are available to achieve the governmental interest. Goldsboro admits that it maintains racially discriminatory policies, and, contrary to Bob Jones University's contention that it is not racially discriminatory, discrimination on the basis of racial affiliation and association is a form of racial discrimination. J., Opinion of the Court CHIEF JUSTICE BURGER delivered the opinion of the Court. To effectuate these views, Negroes were completely excluded until 1971. The University subsequently filed returns under the Federal Unemployment Tax Act for the period from December 1, 1970, to December 31, 1975, and paid a tax [p582] totalling on one employee for the calendar year of 1975. 1150 (DC 1971), with approval, the Court of Appeals concluded that § 501(c)(3) must be read against the background of charitable trust law. For more than 60 years, the IRS and its predecessors have constantly been called upon to interpret these and comparable provisions, and in doing so have referred consistently to principles of charitable trust law. The correctness of the Commissioner's conclusion that a racially discriminatory private school "is not ‘charitable' within the common law concepts reflected in . D The actions of Congress since 1970 leave no doubt that the IRS reached the correct conclusion in exercising its authority. Petitioner Bob Jones University, however, contends that it is not racially discriminatory. 230, defined "racially nondiscriminatory policy as to students" as meaning that the school admits the students of any race to all the rights, privileges, programs, and activities generally accorded or made available to students at that school, and that the school does not discriminate on the basis of race in administration of its educational policies, admissions policies, scholarship and loan programs, and athletic and other school-administered programs. The Solicitor of Internal Revenue looked to the common law of charitable trusts in construing that provision, and noted that "generally bequests for the benefit and advantage of the general public are valid as charities." Sol.


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