Stevens Bros. Foundation, Inc. v. Commissioner of Internal Revenue

MATTHES, Circuit Judge.

'This case is before us on petition to review a decision of the Tax Court which sustained, to a large extent, the Commissioner’s assessment of deficiencies in corporate income and personal holding company taxes, and penalties against Stevens Bros. Foundation, Inc. (Foundation). The questions on review are whether the Tax Court erred in holding that:(1) Foundation had — -(a) not been operated exclusively for charitable purposes during its taxable years 1948 through 1955;(b) unreasonably accumulated income during its taxable years 1952 through 1958;

and therefore that…