Leubuscher v. Commissioner
United States Board of Tax Appeals
1. Bequests to charitable and other corporations of the classes described in section 303(a)(3), Revenue Act of 1924, are deductible, in determining the value of the net estate of a decedent, only when both the organization and operations of the corporation concur in fulfilling the statutory purposes, and then only when the purposes are confined "exclusively" to those expressly described in the statute. 2. A corporation, the organization of which is not only to carry out a…
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1. Bequests to charitable and other corporations of the classes described in section 303(a)(3), Revenue Act of 1924, are deductible, in determining the value of the net estate of a decedent, only when both the organization and operations of the corporation concur in fulfilling the statutory purposes, and then only when the purposes are confined "exclusively" to those expressly described in the statute. 2. A corporation, the organization of which is not only to carry out a charitable or educational object, but also to bring about the adoption of a legislative program, is outside the intendment…
1Opinion of the Court
*1027OPINION.
Stekniiagen :
In the determination of the decedent’s net estate subject to the estate tax imposed by Title III, Revenue Act of 1924, the respondent has disallowed three deductions aggregating $212,-988.43 claimed by the estate under section 303 (a) (3), which is as follows:
Sec. 303. For the purpose of the tax the value of the net estate shall be determined—(a) In the case of a resident, by deducting from the value of the grpss estate—
⅜ * # ⅛ $ #(3) The amount of all bequests, legacies, devises, or transfers, except bona fide sales for a fair consideration in money or money’s worth, in…
2Cases cited1 opinion
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
3Cited by11 opinions
- Golden Rule Church Ass'n v. CommissionerUnited States Tax Court · 1964
- Carson v. CommissionerUnited States Tax Court · 1978
- Carson v. CommissionerUnited States Tax Court · 1978
- Faulkner v. CommissionerUnited States Board of Tax Appeals · 1940
- Golden Rule Church Ass'n v. CommissionerUnited States Tax Court · 1964
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