RALPH H. EATON FOUNDATION v. COMMISSIONER OF INT. REV.

No. 14047.

219 F.2d 527 (1955)

RALPH H. EATON FOUNDATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

February 15, 1955.


Attorney(s) appearing for the Case

Martin H. Webster, Los Angeles, Cal., for appellant.

H. Brian Holland, Asst. Atty. Gen., S. Dee Hanson, Louise Foster, Ellis N. Slack, Sp. Assts. to Atty. Gen., Kenneth W. Gemmill, Acting Chief Counsel, I. R. S., Washington, D. C., for respondent.

Before HEALY, BONE, and POPE, Circuit Judges.


HEALY, Circuit Judge.

This is a proceeding to review an order of the Tax Court determining deficiencies in petitioner's income tax for the period beginning March 1947 and ending January 31, 1949. The question presented is whether a corporation engaged in ordinary business activities for profit is entitled to exemption from income tax under § 101(6) of the Internal Revenue Code, 26 U.S.C.A., solely by reason of the fact that its profits are payable to religious...

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