Cockerline Memorial Fund v. Commissioner
United States Tax Court
P is a testamentary trust. The decedent's will provided that the income of the trust was to be used to furnish scholarships for residents of Oregon who attend colleges and universities in Oregon, with preference to be given to students attending Northwest Christian College.
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P is a testamentary trust. The decedent's will provided that the income of the trust was to be used to furnish scholarships for residents of Oregon who attend colleges and universities in Oregon, with preference to be given to students attending Northwest Christian College. The Commissioner determined that P was a private foundation and not a supporting organization as defined in sec. 509(a)(3), I.R.C. 1954. Held, in view of the historic relationship between P and Northwest, P is a supporting organization within the meaning of sec. 509(a)(3).
1Opinion of the Court
Cockerline Memorial Fund, Petitioner v. Commissioner of Internal Revenue, Respondent
Cockerline Memorial Fund v. Commissioner
Docket No. 11813-83
United States Tax Court
86 T.C. 53; 1986 U.S. Tax Ct. LEXIS 164; 86 T.C. No. 3;
January 21, 1986, Filed
Decision will be entered for the petitioner.
P is a testamentary trust. The decedent's will provided that the income of the trust was to be used to furnish scholarships for residents of Oregon who attend colleges and universities in Oregon, with preference to be given to students attending Northwest Christian College. The Commissioner determined that P…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Change-All Souls Housing Corp. v. United StatesUnited States Court of Claims · 1982
- Warren M. Goodspeed Scholarship Fund, Baybank Merchants, N.A. v. CommissionerUnited States Tax Court · 1978
- Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
- Cockerline Memorial Fund v. CommissionerUnited States Tax Court · 1986
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