Bolton v. Commissioner
United States Tax Court
1. Petitioner gave $ 1,000 a month for the promotion of "Lumia," the art of light in motion. The money was placed in a bank account called the "Light Fund." It could be withdrawn by Wilfred, the discoverer of "Lumia." He used "Art Institute of Light" as a letterhead to arouse interest, and after the taxable years he organized a corporation with that name used on the letterhead. It is conceded that the purposes of Wilfred were educational.
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1. Petitioner gave $ 1,000 a month for the promotion of "Lumia," the art of light in motion. The money was placed in a bank account called the "Light Fund." It could be withdrawn by Wilfred, the discoverer of "Lumia." He used "Art Institute of Light" as a letterhead to arouse interest, and after the taxable years he organized a corporation with that name used on the letterhead. It is conceded that the purposes of Wilfred were educational. Held, that the contributions were to an individual and not to a "trust, or * * * fund" within the meaning of section 505 (a) (2) (B), Revenue Act of 1932 as…
1Opinion of the Court
OPINION.
Hill, Judge:
The first issue is whéther or not petitioner made a deductible gift in each of the taxable years. Respondent contends that the gifts were to an individual and therefore taxable under section 501 of the Revenue Act of 1932. He concedes, however, that the purposes of the work were educational, and thus the issue is limited to whether or not the gifts were “to or for the use of * * * trust, or * * * fund.” Sec. 505 (a) (2) (B), Revenue Act of 1932, as amended by sec. 517, Revenue Act of 1934.
Petitioner contends that the gifts were to a fund or trust and therefore deductible…
2Cases cited1 opinion
- United States v. PelzerSupreme Court of the United States · 1941
3Cited by15 opinions
- Arents v. CommissionerUnited States Tax Court · 1960
- Seligmann v. CommissionerUnited States Tax Court · 1947
- Perkins v. CommissionerUnited States Tax Court · 1943
- Pleet v. CommissionerUnited States Tax Court · 1951
- Roberts v. CommissionerUnited States Tax Court · 1943
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