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BUCKLEY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 134, 135, Dockets 23531, 23532.

231 F.2d 204 (1956)

Aloise S. BUCKLEY and William F. Buckley, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided March 29, 1956.

Attorney(s) appearing for the Case

John E. Boice, Jr. and C. Dean Reasoner, Washington, D. C., Raymond B. Goodell, New York City, of counsel, for petitioners.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Lee A. Jackson, Meyer Rothwacks, Washington, D. C., for respondent.

Before FRANK, LUMBARD and WATERMAN, Circuit Judges.

PER CURIAM.

The facts are set forth in detail in the findings of fact and opinion of the Tax Court, reported at 22 T.C. 1312.

As the Tax Court found, the charters of the "anonymous associations" here involved clearly show a purpose to engage in business activities. This stated purpose is probably conclusive, we think. "The parties are not at liberty to say that their purpose was other or narrower than that which they formally...

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