Legal Opinion

B. Manischewitz Co. v. Commissioner

United States Tax Court

Decided June 22, 1948No. Docket No. 13236PublishedCited by 3 opinions

1. Payments to foreign religious seminary by producer of religious dietary articles held deductible as ordinary and necessary business expense within the meaning of Internal Revenue Code, section 23 (a). 2. Deduction in taxable year on abandonment of experimental electric oven and equipment held proper.

1Opinion of the Court

OPINION.

Opper, Judge:

Because the Hebrew Theological Seminary in Palestine, which was the recipient of petitioner’s payment, does not qualify under Internal Revenue Code, section 23 (q) — defining organizations to which contributions by corporations are deductible— petitioner must seek to establish its right to a deduction as an ordinary and necessary business expense under the more general provisions of section 23 (a).

Such was the posture of all religious and charitable contributions before the Revenue Act of 1935, which, by section 23 (q), first allowed deductions of that nature to be taken…

2Cases cited2 opinions

  1. Smith v. CommissionerUnited States Tax Court · 1944
  2. Singer Sewing Machine Co. v. CommissionerUnited States Tax Court · 1945

3Cited by3 opinions

  1. Stricker v. CommissionerUnited States Tax Court · 1995
  2. B. Manischewitz Co. v. CommissionerUnited States Tax Court · 1948
  3. Nelson Bros., Inc. v. CommissionerUnited States Tax Court · 1992

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