C. F. Mueller Co. v. Commissioner
United States Tax Court
The stock of C. F. Mueller Co. (Mueller) was held in trust for the exclusive benefit of the School of Law of New York University. During the years in issue, Mueller made payments, which it characterized as "charitable contributions" to Law Center Foundation, an exempt organization which was organized and functioned solely for the benefit of the school of law.
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The stock of C. F. Mueller Co. (Mueller) was held in trust for the exclusive benefit of the School of Law of New York University. During the years in issue, Mueller made payments, which it characterized as "charitable contributions" to Law Center Foundation, an exempt organization which was organized and functioned solely for the benefit of the school of law. Held, the purported charitable contributions were made for the benefit of the only entity having a beneficial interest in Mueller and are, in the circumstances of this case, nondeductible dividend distributions. Crosby Valve & Gage Co.…
1Opinion of the Court
Tbe Commissioner determined tbe following deficiencies in petitioner’s Federal income tax for tbe calendar years 1959 tbrongb 1963:
Year Deficiency
1959 _$44,200
1960 _ 44,200
1961_ 39,000
1962 _ 44,200
1963 _ 59,800
Tbe only question presented for decision is wbetber certain payments made by petitioner to tbe Law Center Foundation were deductible as charitable contributions or whether they were in substance nondeductible dividend distributions to or for tbe benefit of New York University.
FINDINGS OF FACT
The parties have stipulated certain facts, which, together with tbe attached exhibits, are…
2Cases cited31 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. CliffordSupreme Court of the United States · 1940
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
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3Cited by8 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- L. C. Bohart Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1975
- C. F. Mueller Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1973
- C. F. Mueller Co. v. CommissionerUnited States Tax Court · 1970
- Edgar v. CommissionerUnited States Tax Court · 1971
3 more not listed; retrieve them via the Exa API.