Sid W. Richardson Foundation v. United States

GEWIN, Circuit Judge:

The Sid W. Richardson Foundation (Foundation) initiated this suit to recover $769,711.48 in income taxes and interest paid by it as transferee of the estate of Sid W. Richardson (Estate) for fiscal years ended September 30, 1960 and September 30, 1961. The sole question presented by the Foundation in its claim for refund, and considered by the district court, was whether the Estate was entitled to deduct from income, as charitable contributions under *711§ 642(e)- I.R.C. of 1954,1 amounts representing undistributed income of Richardson Oils (Oils), a Subchapter S Corporation.…