Danz v. Commissioner
United States Tax Court
1. Exemption -- Section 101 (6) -- Trust Operating Regular Business. -- Congress, in section 101 (6), did not intend to include in the exempt class, as a fund or foundation organized and operated exclusively for charitable purposes, a trust not engaged in charitable work but earning the larger part of its income by the operation of regular substantial businesses, unrelated to the operation of any charity, even though its property must eventually go to corporations of the…
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1. Exemption -- Section 101 (6) -- Trust Operating Regular Business. -- Congress, in section 101 (6), did not intend to include in the exempt class, as a fund or foundation organized and operated exclusively for charitable purposes, a trust not engaged in charitable work but earning the larger part of its income by the operation of regular substantial businesses, unrelated to the operation of any charity, even though its property must eventually go to corporations of the type described in section 23 (o) (2). 2. Income -- Taxable to Grantor -- Charitable Trust -- Section 22 (a) -- Clifford…
1Opinion of the Court
John Danz, Petitioner, et al., * v. Commissioner of Internal Revenue, Respondent
Danz v. Commissioner
Docket Nos. 26402, 26403, 26404, 26405, 26406, 26407, 26408, 33429
United States Tax Court
18 T.C. 454; 1952 U.S. Tax Ct. LEXIS 177;
June 4, 1952, Promulgated
Decisions will be entered under Rule 50.
1. Exemption -- Section 101 (6) -- Trust Operating Regular Business. -- Congress, in section 101 (6), did not intend to include in the exempt class, as a fund or foundation organized and operated exclusively for charitable purposes, a trust not engaged in charitable work but earning the larger part of…
2Cases cited24 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
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