Dillingham Transportation Building, Ltd. v. United States

MADDEN, Judge.

The plaintiff sues for a refund of income taxes paid by it for the years 1946 and 1947. It claims that it was, in those years, a corporation organized and operated exclusively for charitable purposes, and was, therefore, exempt from income tax under section 101(6) of the Internal Revenue Code of 1939, 26 U.S.C. § 101(6).

The plaintiff was organized in Hawaii in 1929 as a business corporation, authorized by its Articles of Association to acquire land, erect office buildings, stores, garage buildings, service stations, to own, lease, operate and maintain office buildings, store…