Peters v. Commissioner
United States Tax Court
Petitioner's contribution in 1948 to Eagle Dock Foundation, Inc., held to be deductible under section 23 (o) (2) of the Code as a charitable contribution.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The sole issue presented here is whether petitioner’s contribution to the Foundation in the taxable year is deductible under section 23 (o) (1) or (2) of the Internal Revenue Code.1
The question chiefly argued by the parties on brief is whether or not petitioner’s donee was organized and operated exclusively for charitable purposes within the meaning of section 23 (o) (2), su-pra. It is petitioner’s position that the evidence adduced herein conclusively establishes the charitable nature of the purposes underlying the organization and operation of the Foundation. To…
2Cases cited2 opinions
- Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877
- T. J. Moss Tie Co. v. CommissionerUnited States Tax Court · 1952
3Cited by8 opinions
- Columbia Park & Recreation Asso. v. CommissionerUnited States Tax Court · 1987
- Staman v. Board of AssessorsMassachusetts Supreme Judicial Court · 1966
- Hutchinson Baseball Enterprises, Inc. v. CommissionerUnited States Tax Court · 1979
- Hutchinson Baseball Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1982
- Columbia Park & Recreation Asso. v. CommissionerUnited States Tax Court · 1987
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