Legal Opinion
C. F. Mueller Co. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 20, 1951No. 10266PublishedCited by 99 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
This petition for review of the decision of the ,Tax Court affects the liability of the petitioner, C. F. Mueller Company, for income taxes from August 28 to December 31, 1947. The issue presented is whether petitioner was exempt from income taxes as a corporation organized and operated exclusively for charitable purposes within Section 101(6) 1 of the Internal Revenue Code, 26 U.S.C., 1946 ed. § 101(6). The Tax Court held that it was not, 14 T.C. 922. What we do here with the problem is of little importance for the future, since Congress has entered the area of…
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