Stoeckel v. Commissioner
United States Tax Court
Where the facts fail to show that the social aspect of a club's organization was only incidental to a primary purpose of furthering higher education, it is held that the club was not organized exclusively for educational, literary, or charitable purposes within the purview of section 812 (d) of the Internal Revenue Code.
1Opinion of the Court
opinion.
Arundell, Jvdge:
This proceeding involves a deficiency in estate tax determined by the Commissioner in the amount of $18,968.40, The dispute arises from the Commissioner’s holding that a bequest of $60,000 was not deductible from gross estate because the donee, the Litchfield County University Club, herein known as the club, was not “organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes” within the meaning of section 812 (d) of the Internal Revenue Code. Petitioners are the executors of the estate of the donor, Ellen Battell…
2Cited by6 opinions
- Huntington Nat'l Bank v. CommissionerUnited States Tax Court · 1949
- Marshall v. CommissionerUnited States Tax Court · 1943
- Estate of George H. Wadleigh v. CommissionerUnited States Tax Court · 1945
- Huntington Nat'l Bank v. CommissionerUnited States Tax Court · 1949
- Marshall v. CommissionerUnited States Tax Court · 1943
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