Legal Opinion

Ralph H. Eaton Foundation v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided February 15, 1955No. 14047_1PublishedCited by 33 opinions

1Opinion of the Court

HEALY, Circuit Judge.

This is a proceeding to review an order of the Tax Court determining deficiencies in petitioner’s, income tax for the period beginning March 1947 and ending January 31, 1949. The question presented is whether a corporation engaged in ordinary business activities for profit is entitled to exemption from income tax under § 101(6) of the Internal Revenue Code, 26 U.S.C.A., solely by reason of the fact that its profits are payable to religious, charitable or educational enterprises.

Petitioner was organized under the laws of Arizona in March, 1947. Its in-corporators and…

2Cases cited3 opinions

  1. United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
  2. Squire v. Students Book CorpCourt of Appeals for the Ninth Circuit · 1951
  3. Bear Gulch Water Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1941

3Cited by33 opinions

  1. The John Danz Charitable Trust v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
  2. Samuel Friedland Foundation v. United StatesDistrict Court, D. New Jersey · 1956
  3. Commissioner of Internal Revenue v. John Danz Charitable TrustCourt of Appeals for the Ninth Circuit · 1960
  4. Peggy Lou Riker and Freda H. Grassmee v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  5. Randall Foundation, Inc. v. Robert A. Riddell, Director of Internal Revenue, District of Los AngelesCourt of Appeals for the Ninth Circuit · 1957

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