Havemeyer v. Commissioner
United States Board of Tax Appeals
The petitioner, together with members of his family and a close business associate, organized an unincorporated association to unite and coordinate their charitable activities. The contributions to the association in the taxable year were practically all made by petitioner and members of his family.
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The petitioner, together with members of his family and a close business associate, organized an unincorporated association to unite and coordinate their charitable activities. The contributions to the association in the taxable year were practically all made by petitioner and members of his family. The distributions of the association in the taxable year were all made to or for the benefit of individuals or relatives thereof who had served the petitioner or his family as employees or otherwise. Held, association was not organized nor operated during the taxable year exclusively for…
1Opinion of the Court
Opinion.
Mellott :
The Commissioner determined a deficiency in petitioner’s income tax for the year 1932 in the amount of $529.31. Petitioner apparently concede that certain minor adjustments were properly made, but assigns as error the Commissioner’s disallowance of $2,236.80 of $3,180.60 deducted by him in his return for said year as contributions.
The facts were stipulated, but at the hearing petitioner offered as exhibits the re.urns of the association hereinafter referred to for the years 1918 to 1932, inclusive, and such returns were received in evidence. The facts may be summarized for…
2Cases cited5 opinions
- Helvering v. BlissSupreme Court of the United States · 1934
- Old Mission Portland Cement Co. v. HelveringSupreme Court of the United States · 1934
- Perin Ex Rel. Perin v. CareySupreme Court of the United States · 1861
- Kain v. GibboneySupreme Court of the United States · 1879
- Smith v. Havens Belief Fund SocietyAppellate Division of the Supreme Court of the State of New York · 1907
3Cited by1 opinion
- Havemeyer v. CommissionerUnited States Board of Tax Appeals · 1937