Buscaglia v. Tax Court of Puerto Rico

DISSENTING OPINION DELIVERED BY

MR. JUSTICE TOOI), JR.

As it is admitted in the opinion of the majority, the decisions on tills question are divided. I have read the cases cited by the Tax Court and, in my opinion, they warrant and support the conclusion which it reached. The law does not require that the institution be devoted exlusively to charitable purposes in order to be exempt and, even under statutes which so provide, it has been held that they are, especially when the institution is organized for non-pecuniary purposes and the members do not receive any dividend.

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