Patterson v. Commissioner
United States Board of Tax Appeals
1. Where the decedent, a stockholder of a corporation, donated a large sum of money to two officers of the corporation "as a trust fund to be used to loan to or assist employees, former employees, or their families, or dependents, as in their judgment may be of assistance", the contribution is deductible under section 23(n) of the Revenue Act of 1928 as a contribution for a charitable purpose. 2. Where the trust instrument transferring the gift for charitable purposes…
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1. Where the decedent, a stockholder of a corporation, donated a large sum of money to two officers of the corporation "as a trust fund to be used to loan to or assist employees, former employees, or their families, or dependents, as in their judgment may be of assistance", the contribution is deductible under section 23(n) of the Revenue Act of 1928 as a contribution for a charitable purpose. 2. Where the trust instrument transferring the gift for charitable purposes contained a provision requiring the trustees to keep a record of what they did and submit it to the donor from time to time…
1Opinion of the Court
PROCTOR PATTERSON AND EARL P. DISBRO, EXECUTORS UNDER THE WILL OF MARION C. TYLER, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Patterson v. Commissioner
Docket No. 75719.
United States Board of Tax Appeals
34 B.T.A. 689; 1936 BTA LEXIS 660;
June 12, 1936, Promulgated
1. Where the decedent, a stockholder of a corporation, donated a large sum of money to two officers of the corporation "as a trust fund to be used to loan to or assist employees, former employees, or their families, or dependents, as in their judgment may be of assistance", the contribution is deductible…
2Cases cited20 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- In Re the Probate of the Will of RobinsonNew York Court of Appeals · 1911
- Dickerson's AppealSupreme Court of Pennsylvania · 1887
- Gray v. Union Trust Co.California Supreme Court · 1915
- Woodruff v. MarshSupreme Court of Connecticut · 1893
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