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TEXAS TRADE SCHOOL v. COMMISSIONER OF INTERNAL REVENUE

No. 17740.

272 F.2d 168 (1959)

TEXAS TRADE SCHOOL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

November 25, 1959.

Attorney(s) appearing for the Case

Allen Melton, Dallas, Tex., for petitioner.

Rita E. Hauser, Atty., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., Howard A. Heffron, Act. Asst. Atty. Gen., Lee A. Jackson, Atty., Marvin W. Weinstein, Atty., Arch M. Cantrall, Chief Counsel, Charles P. Dugan, Special Atty., Washington, D. C., Internal Revenue Service, for respondent.

Before HUTCHESON, JONES and WISDOM, Circuit Judges.

PER CURIAM.

The Commissioner of Internal Revenue determined that Texas Trade School, petitioner, was not entitled to exemption from taxation under Section 101(6) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 101(6). This section exempts from taxation corporations organized and operated exclusively for educational purposes, no part of the net earnings of which inures to the benefit of any prior shareholder or individual. The basis for this determination...

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