Legal Opinion

Sibley v. Commissioner

United States Board of Tax Appeals

Decided June 5, 1929No. Docket No. 24921PublishedCited by 7 opinions

CONTRIBUTIONS - EXEMPT CORPORATIONS. - A corporation organized and operated solely for the purpose of extending aid to the employees of a large department store in cases of death or disability, and which derives its income solely from voluntary contributions and interest on investments, is an exempt corporation as defined in section 231(6) of the Revenue Act of 1921, and contributions thereto by an individual are deductible pursuant to section 214(a)(11) of the Revenue Act…

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CONTRIBUTIONS - EXEMPT CORPORATIONS. - A corporation organized and operated solely for the purpose of extending aid to the employees of a large department store in cases of death or disability, and which derives its income solely from voluntary contributions and interest on investments, is an exempt corporation as defined in section 231(6) of the Revenue Act of 1921, and contributions thereto by an individual are deductible pursuant to section 214(a)(11) of the Revenue Act of 1921.

1Opinion of the Court

*916OPINION.

Milliken :

The question presented by this proceeding depends on whether the employees’ association is an exempt organization as defined in section 231(6) of the Revenue Act of 1921, and whether the contribution made by Rufus A. Sibley is allowable as a deduction in the computation of net income under section 214(a) (11), Revenue Act of 1921.

*917Section 231(6) provides:

That the following organizations shall be exempt from taxation under this title:

* * * * * * *(6) Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable,…

2Cases cited1 opinion

  1. Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877

3Cited by7 opinions

  1. Harrison v. Barker Annuity FundCourt of Appeals for the Seventh Circuit · 1937
  2. Chase v. CommissionerUnited States Tax Court · 1960
  3. Policemen's Benevolent Asso. v. CommissionerUnited States Tax Court · 1981
  4. Casey v. CommissionerUnited States Tax Court · 1965
  5. Estate of Isabelle Scudder Farrington v. CommissionerUnited States Tax Court · 1946

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