Duffy v. Birmingham

RIDDICK, Circuit Judge.

The question is whether taxpayer, the Eastman Memorial Trust, was organized and operated exclusively for charitable purposes within the meaning of section 101 (6) of the Internal Revenue Code, 26 U.S.C., 1946 Edition, section 101(6), which exempts from income taxation, “Corporations, and any community chest, fund, or foundation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private…