Legal Opinion
R. L. Phinney, District Director of Internal Revenue v. J. Chrys Dougherty Et Ux.
Court of Appeals for the Fifth Circuit
Decided October 11, 1962No. 19195PublishedCited by 8 opinions
1Opinion of the Court
RIVES, Circuit Judge.
The question is whether the taxpayers’ gift in 1957 to Texas Beta Students Aid Fund (hereafter Fund) was a gift to a corporation “organized and operated exclusively for * * * educational purposes” within the meaning of section 170 (c) (2) 1 [see also section 501(e) (3)] of the Internal Revenue Code of 1954, 26 U.S.C.A. § 170(c) (2), and hence deductible in computing their income tax liability for that year, all other requirements as to deductibility admittedly being present.
The Fund was incorporated as a nonprofit corporation under the laws of Texas in 1947. Its purposes…
2Cases cited2 opinions
- Davison v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Davison v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by8 opinions
- E. H. Winn, Jr. And Betty Lee Jones Winn v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- People's Educational Camp Soc. v. CommissionerUnited States Tax Court · 1963
- United States ex rel. Hutcheson v. HoffmanCourt of Appeals for the Fifth Circuit · 1971
- PI Lambda Phi Fraternity, Inc. v. University of PittsburghDistrict Court, W.D. Pennsylvania · 1999
- Alumnae Chapter Beta of Clovia v. CommissionerUnited States Tax Court · 1983
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