Leon A. Beeghly Fund v. Commissioner
United States Tax Court
1. Held, petitioner was not exempt from tax under section 101(6), I.R.C. 1939, during the year 1949. 2. Held, petitioner is entitled to a deduction for the year 1949, under section 162(a), I.R.C. 1939, relating to charitable deductions of trusts, of an amount at least equal to its net income for that year.
1Opinion of the Court
DRennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for the year 1949 in the amount of $10,280,673.27. The deficiency results from respondent’s determination that petitioner was not an exempt organization in 1949 and that an accumulation of patent royalties and infringement claims, totaling $15,366,841.12, which had been paid into the registry of various courts by orders of those courts in various patent litigations and which were released to petitioner in 1949 was taxable in its entirety as ordinary income to petitioner in 1949.
The issues were, first, whether…
2Cases cited16 opinions
- C. F. Mueller Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1937
- United States v. Community Services, Inc.Court of Appeals for the Fourth Circuit · 1951
- Danz v. CommissionerUnited States Tax Court · 1952
- Levers v. AndersonSupreme Court of the United States · 1945
11 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Stevens Bros. Foundation, Inc. v. CommissionerUnited States Tax Court · 1962
- Waller v. CommissionerUnited States Tax Court · 1963
- Sound Health Ass'n v. CommissionerUnited States Tax Court · 1978
- Commissioner of Internal Revenue v. The Leon A. Beeghly Fund, the Union National Bank of Youngstown, Ohio, TrusteeCourt of Appeals for the Sixth Circuit · 1962
14 more not listed; retrieve them via the Exa API.