Tax Comm. v. American Humane Educational Society

It is also conceded that the section of the Code was amended for the purpose of exempting bequests to charitable institutions whose activities were carried on/in substantial part in the state of Ohio.

Do the expenditures made by the American Humane Education Society in Ohio constitute a substantial part of the activities of that association?

Counsel for plaintiff in error adopt the definition of “substantial” as found in Funk & Wagnalls Standard Dictionary as follows: “Of real worth and importance; of considerable value; valuable.”

We are disposed to accept this as a correct definition of what…