Legal Opinion

Journal of Accountancy v. Commissioner

United States Board of Tax Appeals

Decided June 29, 1929No. Docket No. 15946PublishedCited by 3 opinions

The petitioner is not a corporation organized and operated exclusively for scientific, literary or educational purposes. Its only stockholder, the American Institute of Accountants, is a private stockholder within the meaning of section 231(6) of the Revenue Act of 1921.

1Opinion of the Court

*1263ORINION.

Mukdock:

The petitioner claims exemption under the following section of the Bevenue Act of 1921:

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

*******(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.

It contends that it was organized and operated exclusively for…

2Cases cited9 opinions

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  2. Coyle v. GraySupreme Court of Delaware · 1884
  3. Downing v. Indiana State Board of AgricultureIndiana Supreme Court · 1891
  4. Bonaparte v. Camden & A. R.U.S. Circuit Court for the District of New Jersey · 1830
  5. Chamberlain v. City of BurlingtonSupreme Court of Iowa · 1865

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3Cited by3 opinions

  1. Washington Park Cemetery Asso. v. CommissionerUnited States Tax Court · 1963
  2. Goldsby King Mem. Hosp. v. CommissionerUnited States Tax Court · 1944
  3. Journal of Accountancy v. CommissionerUnited States Board of Tax Appeals · 1929

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