Gladney v. Commissioner
United States Tax Court
D died in 1905, bequeathing certain property in trust, the donee to be incorporated, to found and maintain a home for aged and infirm men. The donee organization was ruled tax-exempt by respondent in 1950. The number of residents at the home declined, its expenses increased, and part of the organization's capital was used to pay the resulting excess of expenses over income. On July 1, 1971, the organization closed the home for financial reasons.
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D died in 1905, bequeathing certain property in trust, the donee to be incorporated, to found and maintain a home for aged and infirm men. The donee organization was ruled tax-exempt by respondent in 1950. The number of residents at the home declined, its expenses increased, and part of the organization's capital was used to pay the resulting excess of expenses over income. On July 1, 1971, the organization closed the home for financial reasons. One November 5, 1971, D's heirs, the petitioners in these cases, brought a declaratory judgment action to have the Louisiana Civil District Court…
1Opinion of the Court
WILLIAM KELLY GLADNEY, EVELYN GLADNEY WITHERSPOON, CELESTE GLADNEY PEERS, JULIAN M. GLADNEY, and EDWARD LEE GLADNEY, Transferees, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; WILLIAM F. BONNER, JR., ESTATE OF BETTINA BONNER, WILLIAM F. BONNER, JR., Executor, Transferee, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gladney v. Commissioner
Docket Nos. 6294-77, 6355-77.
United States Tax Court
T.C. Memo 1982-708; 1982 Tax Ct. Memo LEXIS 40; 45 T.C.M. (CCH) 280; T.C.M. (RIA) 82708;
December 6, 1982.
D died in 1905, bequeathing certain property in trust, the donee to be…
2Cases cited6 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Yagoda v. CommissionerUnited States Tax Court · 1962
- Gottesman & Co. v. CommissionerUnited States Tax Court · 1981
- Corn Belt Hatcheries, Inc. v. CommissionerUnited States Tax Court · 1969
- Bonner v. Board of TrusteesLouisiana Court of Appeal · 1965
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Gladney v. CommissionerCourt of Appeals for the Fifth Circuit · 1984
- William Kelly Gladney, Evelyn Gladney Witherspoon, Celeste Gladney Peers, Julian M. Gladney and Edward Lee Gladney, Transferees v. Commissioner of Internal Revenue, William F. Bonner, Jr., Estate of Bettina Bonner, William F. Bonner, Jr., Transferees, Appellees-Cross-Appellants v. Commissioner of Internal Revenue, Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1984