Broadview Sav. & Loan Co. v. Commissioner

*728OPINION.

TRAMmell:

The petitioner here contends that it is exempt from income' taxation for the calendar year 1922 under the provisions of section 231 (4) of the Revenue Act of 1921, the pertinent part of which reads as follows:

Sec. 231. That the following organizations shall be exempt from taxation under this title — ■

[[Image here]](4) Domestic building and loan associations substantially all the business of which is confined to making loans to members; * * *

The respondent denied the petitioner’s claim- for exemption, and determined the deficiency involved herein. The burden is, therefore,…