Berkeley Hall School, Inc. v. Commissioner
United States Board of Tax Appeals
1. EXEMPTION - CHARITABLE ORGANIZATION. - Where a corporation is not both "organized and operated exclusively" for educational or other purposes named in the Revenue Act of 1924, section 231 (6), held it is not exempt from income tax thereunder.
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1. EXEMPTION - CHARITABLE ORGANIZATION. - Where a corporation is not both "organized and operated exclusively" for educational or other purposes named in the Revenue Act of 1924, section 231 (6), held it is not exempt from income tax thereunder. James Sprunt Benevolent Trust,20 B.T.A. 19, followed. 2. INCOME - TRUSTEE FOR CHARITABLE PURPOSE. - Where certain individuals caused certain property to be conveyed to petitioner without cost to it with the understanding that such property together with the income derived from its sale, was to be devoted to a definite charitable use, namely, the…
1Opinion of the Court
*1122OPINION.
Leech:
The petitioner is a corporation which owned and operated a school for children of persons in Los Angeles, California, who were interested in Christian Science. It was about to discontinue this school in 1923 because of a lack of necessary facilities. When the parents of some of the students of the school learned of its proposed discontinuance they discussed the situation among themselves and finally adopted a plan to secure necessary real estate and a sufficient sum of money to provide and perpetuate in Los Angeles a school for children of persons interested in Christian…
2Cases cited16 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Corliss v. BowersSupreme Court of the United States · 1930
- Freuler v. HelveringSupreme Court of the United States · 1934
- Brison v. BrisonCalifornia Supreme Court · 1888
- Russell v. AllenSupreme Court of the United States · 1883
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3Cited by1 opinion
- Berkeley Hall School, Inc. v. CommissionerUnited States Board of Tax Appeals · 1935