Bilingual Montessori School, Inc. v. Commissioner
United States Tax Court
Petitioner, a corporation organized under the laws of the State of Delaware which is exempt from taxation under sec. 501(c)(3), I.R.C. 1954, operates a private school in Paris, France. Held, since petitioner is a corporation created or organized under the law of a State within the meaning of sec. 170(c)(2)(A), contributions to or for the use of petitioner are deductible under sec. 170(a).
1Opinion of the Court
OPINION
Ekman, Judge:
This is an action for declaratory relief brought by Bilingual Montessori School of Paris, Inc. (hereinafter petitioner), against respondent under section 7428 of the Internal Revenue Code of 1954. The statutory prerequisites for declaratory judgment have been satisfied. The only issue before the Court is whether petitioner is an organization described in section 170(c)(2)(A) so that contributions to petitioner will be deductible under section 170(a).
This case was submitted for decision on a stipulated-administrative record under Rules 122 and 217, Tax Court Rules of…
2Cases cited9 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. MunterSupreme Court of the United States · 1947
- United States v. Cambridge Loan & Building Co.Supreme Court of the United States · 1928
- Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
- Galt v. CommissionerUnited States Tax Court · 1953
4 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Clark v. CommissionerUnited States Tax Court · 1988
- Kessler v. CommissionerUnited States Tax Court · 1986
- Estate of Wall v. CommissionerUnited States Tax Court · 1993
- Bilingual Montessori School, Inc. v. CommissionerUnited States Tax Court · 1980
- Clark v. CommissionerUnited States Tax Court · 1988
2 more not listed; retrieve them via the Exa API.