Estate of Blaine v. Commissioner

OPINION.

Raum, Judge:

The question before us is not whether the Foundation for World Government is exempt from income taxes. The Commissioner has already ruled that the Foundation is exempt under section 101 (8) of the Internal Revenue Code of 1939,4 which deals with organizations, among others, “not organized for profit but operated exclusively for the promotion of social welfare *' * *.” The questions before us are (1) whether the transfers made by Mrs. Blaine to the Foundation are deductible from her gross income under section 23 (o) (2) ,5 and (2) whether .such transfers are deductible for…