Berkeley Hall School, Inc. v. Commissioner
United States Board of Tax Appeals
1. EXEMPTION - CHARITABLE ORGANIZATION. - Where a corporation is not both "organized and operated exclusively" for educational or other purposes named in the Revenue Act of 1924, section 231 (6), held it is not exempt from income tax thereunder.
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1. EXEMPTION - CHARITABLE ORGANIZATION. - Where a corporation is not both "organized and operated exclusively" for educational or other purposes named in the Revenue Act of 1924, section 231 (6), held it is not exempt from income tax thereunder. James Sprunt Benevolent Trust,20 B.T.A. 19, followed. 2. INCOME - TRUSTEE FOR CHARITABLE PURPOSE. - Where certain individuals caused certain property to be conveyed to petitioner without cost to it with the understanding that such property together with the income derived from its sale, was to be devoted to a definite charitable use, namely, the…
1Opinion of the Court
BERKELEY HALL SCHOOL, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Berkeley Hall School, Inc. v. Commissioner
Docket No. 47415.
United States Board of Tax Appeals
31 B.T.A. 1116; 1935 BTA LEXIS 1021;
January 24, 1935, Promulgated
1. EXEMPTION - CHARITABLE ORGANIZATION. - Where a corporation is not both "organized and operated exclusively" for educational or other purposes named in the Revenue Act of 1924, section 231 (6), held it is not exempt from income tax thereunder. James Sprunt Benevolent Trust,20 B.T.A. 19, followed.
2. INCOME - TRUSTEE FOR CHARITABLE PURPOSE. - Where…
2Cases cited2 opinions
- Sprunt Benevolent Trust v. CommissionerUnited States Board of Tax Appeals · 1930
- Berkeley Hall School, Inc. v. CommissionerUnited States Board of Tax Appeals · 1935