Nellie Callahan Scholarship Fund v. Commissioner
United States Tax Court
Petitioner is a testamentary trust. The decedent's will, which is petitioner's organizing document, specified that the income of the trust was to be used to provide college scholarships for members of the graduating class of Winterset, Iowa, Community High School.
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Petitioner is a testamentary trust. The decedent's will, which is petitioner's organizing document, specified that the income of the trust was to be used to provide college scholarships for members of the graduating class of Winterset, Iowa, Community High School. The Commissioner determined that petitioner was a private foundation, and not a supporting organization as defined in sec. 509(a)(3), I.R.C. 1954. The Commissioner relied solely on the ground that petitioner was not "operated * * * in connection with" a publicly supported charity as required by sec. 509(a)(3)(B) and sec.…
1Opinion of the Court
Nellie Callahan Scholarship Fund, a Trust Under the Will of Nellie Callahan, Deceased, Trustees Larry Jackson, Kenneth Bassett, Clifford Scholten, Shirley A. Webster, and Iowa-Des Moines National Bank, Petitioner v. Commissioner of Internal Revenue, Respondent
Nellie Callahan Scholarship Fund v. Commissioner
Docket No. 9512-77X
United States Tax Court
73 T.C. 626; 1980 U.S. Tax Ct. LEXIS 208;
January 3, 1980, Filed
Decision will be entered for the petitioner.
Petitioner is a testamentary trust. The decedent's will, which is petitioner's organizing document, specified that the income of the trust was…
2Cases cited4 opinions
- Taft v. HelveringSupreme Court of the United States · 1940
- Warren M. Goodspeed Scholarship Fund, Baybank Merchants, N.A. v. CommissionerUnited States Tax Court · 1978
- Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
- Nellie Callahan Scholarship Fund v. CommissionerUnited States Tax Court · 1980