C. F. Smith Co. v. Commissioner
United States Tax Court
1. Petitioner manufactured and sold shirts and leather goods. Its articles of incorporation recited that it was formed to "foster and promote Christian, religious, charitable and educational enterprises" and that it did not "contemplate pecuniary gain or profit to the members thereof and shall have no capital stock." The articles made no provision for the disposition of earnings or assets.
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1. Petitioner manufactured and sold shirts and leather goods. Its articles of incorporation recited that it was formed to "foster and promote Christian, religious, charitable and educational enterprises" and that it did not "contemplate pecuniary gain or profit to the members thereof and shall have no capital stock." The articles made no provision for the disposition of earnings or assets. The by-laws, which could be amended or repealed by the directors, provided that a substantial portion of each year's earnings would be retained by petitioner, and that in the event of petitioner's…
1Opinion of the Court
C. F. Smith Company v. Commissioner.
C. F. Smith Co. v. Commissioner
Docket No. 32973.
United States Tax Court
T.C. Memo 1954-86; 1954 Tax Ct. Memo LEXIS 157; 13 T.C.M. (CCH) 607; T.C.M. (RIA) 54191;
June 30, 1954, Filed
1. Petitioner manufactured and sold shirts and leather goods. Its articles of incorporation recited that it was formed to "foster and promote Christian, religious, charitable and educational enterprises" and that it did not "contemplate pecuniary gain or profit to the members thereof and shall have no capital stock." The articles made no provision for the disposition of earnings or…
2Cases cited4 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
- C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1950
- Roche's Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1937
3Cited by1 opinion
- Whipple Chrysler-Plymouth v. CommissionerUnited States Tax Court · 1972