JOSEPH AND LOTTIE RABINOVITZ FOUNDATION v. COMMISSIONER

Docket No. 57780.

17 T.C.M. 958 (1958)

T.C. Memo. 1958-193

The Joseph and Lottie Rabinovitz Foundation, Joseph Rabinovitz, Trustee v. Commissioner.

United States Tax Court.

Filed November 20, 1958.


Attorney(s) appearing for the Case

William Shelmerdine, Jr., Esq., 75 Federal Street, Boston, Mass., for the petitioner. Chester M. Howe, Esq., for the respondent.


Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined deficiencies in income tax of $4,135.66 for 1948 and $42.35 for 1950.

The questions presented are whether the petitioner was "organized and operated exclusively for * * * charitable * * * purposes" within the meaning of section 101(6) of the I. R. C. of 1939, and, alternatively, whether undistributed income of the years in question was deductible as "permanently set aside" for charitable...

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