Du Bois v. Commissioner
United States Board of Tax Appeals
The petitioner organized a corporation exclusively for charitable, etc., purposes, to which he made all of the contributions received by it during the taxable year, with one minor exception. The corporation made some donations in that year to several charitable organizations, but donated the principal part of its receipts to relatives of the petitioner and an old family employee.
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The petitioner organized a corporation exclusively for charitable, etc., purposes, to which he made all of the contributions received by it during the taxable year, with one minor exception. The corporation made some donations in that year to several charitable organizations, but donated the principal part of its receipts to relatives of the petitioner and an old family employee. Held, the corporation was not operated during the taxable year exclusively for charitable purposes within the meaning of section 23(n)(2), Revenue Act of 1928.
1Opinion of the Court
*240OPINION.
Murdock :
The only question for decision in this case is whether or not the Keystone Foundation, Inc., was operated during 1931 exclusively for charitable purposes within the meaning of section 23 (n) (2) of the Revenue Act of 1928. The petitioner claims that it was and, therefore, his contributions to it are deductible, subject to the 15 percent limitation. But the Commissioner has held that it was not operated exclusively for such purposes and contends that it was operated principally for private purposes which were personal to the petitioner.
The petitioner testified in regard to his…
2Cases cited1 opinion
- Sprunt Benevolent Trust v. CommissionerUnited States Board of Tax Appeals · 1930
3Cited by10 opinions
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Boyer v. CommissionerUnited States Tax Court · 1977
- George W. Griffin, Jr., and William R. Griffin, Co-Executors of the Estate of George W. Griffin, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1968
- Morrell v. CommissionerCourt of Appeals for the Third Circuit · 1939
- Canal National Bank v. United StatesDistrict Court, D. Maine · 1966
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