State v. Fulton Foundation

Appellant poses two questions: 1. Was it the intent of the testator that his bequest to the Foundation be restricted to use by the Foundation exclusively within Wisconsin; 2. If it was not, can the directors of the Foundation so restrict its use to obtain the exemption provided by sec. 72.04 (1), Stats.?

The statute provides:

“The following exemptions from the tax are hereby allowed :

“(1) All property transferred ... to corporations or voluntary associations organized under the laws of this state, solely for religious, humane, charitable, or educational purposes, . . . which shall use the…