Sprunt Benevolent Trust v. Commissioner
United States Board of Tax Appeals
1. The petitioner was not organized exclusively for religious, charitable, scientific, literary, or educational purposes and is not exempt from taxation under section 231 of the Revenue Act of 1921. 2. Certain amounts were permanently set aside by the petitioner during the years 1922 and 1923 for charitable and like purposes specified in section 214(a)(11) of the Revenue Act of 1921 and are deductible in those years.
1Opinion of the Court
*23OPINION.
Smith :
The petitioner contends, first, that it is exempt from taxation under section 231 of the Revenue Act of 1921. This section reads in part as follows:
*24That the following organizations shall be exempt from taxation under this title—
* * s{< * #(6) Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual.
The respondent,…
2Cases cited2 opinions
- Perin Ex Rel. Perin v. CareySupreme Court of the United States · 1861
- Kain v. GibboneySupreme Court of the United States · 1879
3Cited by9 opinions
- Du Bois v. CommissionerUnited States Board of Tax Appeals · 1934
- George W. Griffin, Jr., and William R. Griffin, Co-Executors of the Estate of George W. Griffin, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1968
- Canal National Bank v. United StatesDistrict Court, D. Maine · 1966
- State v. First National Bank of MonroeWisconsin Supreme Court · 1978
- Berkeley Hall School, Inc. v. CommissionerUnited States Board of Tax Appeals · 1935
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