Edward Orton, Ceramic Foundation v. Commissioner
United States Tax Court
The petitioner, a foundation organized under the founder's will for the purpose of aiding and promoting the science of ceramic engineering, held, exempt from income tax under section 101 (6) of the Internal Revenue Code, notwithstanding that it acquired, under the will, and operated a going business consisting of the manufacture and sale of pyrometric cones, and, out of its income, paid a life annuity to the founder's widow.
1Opinion of the Court
OPINION.
LeMire, Judge:
The petitioner’s contention here is that it is exempt from tax under the provisions of section 101 (6) of the Internal Eeve-nue Code. That section provides exemption from income tax for:
Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, literary, or educational ■ purppses, 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 shareholder or individual, and no substantial part of the activities of which is carrying…
2Cases cited4 opinions
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- Helvering v. BlissSupreme Court of the United States · 1934
- Lederer v. StocktonSupreme Court of the United States · 1922
- Missouri Historical Society v. Academy of ScienceSupreme Court of Missouri · 1887
3Cited by21 opinions
- Saint Germain Foundation v. CommissionerUnited States Tax Court · 1956
- Birmingham Business College, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1960
- F. E. McGillick Co. v. CommissionerUnited States Tax Court · 1958
- Gemological Institute of America v. CommissionerUnited States Tax Court · 1952
- Birmingham Business College, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
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