Edward Orton, Jr., Ceramic Foundation v. Commissioner
United States Tax Court
Complying with the terms of Edward Orton, Jr.'s will the trustees of the Edward Orton, Jr., Ceramic Foundation took over and operated the testator's pyrometric cone manufacturing business, and applied the profits therefrom to research in the field of ceramic engineering.
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Complying with the terms of Edward Orton, Jr.'s will the trustees of the Edward Orton, Jr., Ceramic Foundation took over and operated the testator's pyrometric cone manufacturing business, and applied the profits therefrom to research in the field of ceramic engineering. Held, for the years 1962, 1963, and 1964 petitioner was an organization of the type described in sec. 501(c)(3) and is thus exempt from taxation for those years under sec. 501(a). Edward Orton, Jr. Ceramic Foundation, 9 T.C. 533 (1947), affd. 173 F. 2d 483 (C.A. 6, 1949), followed. Held, further, petitioner is not a feeder…
1Opinion of the Court
Sterrett, Judge:
The Commissioner determined the following deficiencies in petitioner’s Federal income taxes:1
Taxable year Deficiency
1962 _$19,368
1963 _ 7,789
1964 _ 20,105
In an amended answer respondent determined the following alternative deficiencies:
Taxable year Deficiency
1962 ___ $16, 233
1963 _ 5,209
1964 _ 17, 328
We are to decide whether petitioner for the years in issue fails to qualify as an organization exempt from taxation under section 501 (c)(3),2 or is a feeder organization under section 502, or, in the alternative, is the recipient of unrelated-business income under sections…
2Cases cited13 opinions
- Cook v. TaitSupreme Court of the United States · 1924
- Parker v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
- Scripture Press Foundation v. United StatesUnited States Court of Claims · 1961
- Commissioner of Internal Revenue v. OrtonCourt of Appeals for the Sixth Circuit · 1949
- Fides Publishers Ass'n v. United StatesDistrict Court, N.D. Indiana · 1967
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3Cited by25 opinions
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- Aid to Artisans, Inc. v. CommissionerUnited States Tax Court · 1978
- Dumaine Farms v. CommissionerUnited States Tax Court · 1980
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