Legal Opinion

Julia R. & Estelle L. Foundation, Inc. v. Commissioner

United States Tax Court

Decided April 5, 1978No. Docket No. 6263-76Published

Petitioner, a private foundation, incurred expenses attributable in part to its investment activities and in part to its making distributions to public charitable, educational, and scientific organizations. Held, only the investment-related expenses are deductible in calculating net investment income under sec. 4940, I.R.C. 1954.

1Opinion of the Court

Julia R. & Estelle L. Foundation, Incorporated, Petitioner v. Commissioner of Internal Revenue, Respondent

Julia R. & Estelle L. Foundation, Inc. v. Commissioner

Docket No. 6263-76

United States Tax Court

70 T.C. 1; 1978 U.S. Tax Ct. LEXIS 141;

April 5, 1978, Filed

Decision will be entered for the respondent.

Petitioner, a private foundation, incurred expenses attributable in part to its investment activities and in part to its making distributions to public charitable, educational, and scientific organizations. Held, only the investment-related expenses are deductible in calculating net investment…

2Cases cited18 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Bingler v. JohnsonSupreme Court of the United States · 1969
  3. United States v. GilmoreSupreme Court of the United States · 1963
  4. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  5. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934

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