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WARDWELL'S ESTATE v. C. I. R.

No. 16799.

301 F.2d 632 (1962)

ESTATE of O. J. WARDWELL, Deceased, Ruth A. Ingersoll, Administratrix with Will Annexed; and Estate of Marjorie M. Wardwell, Deceased, Ruth A. Ingersoll, Executrix, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

April 5, 1962.

Attorney(s) appearing for the Case

Maurice E. Stark, Fort Dodge, Iowa and Robert D. Blue, Eagle Grove, Iowa, for petitioners.

C. Guy Tadlock, Attorney, Department of Justice, Washington, D. C., John B. Jones, Jr., Acting Asst. Atty. Gen., Washington, D. C. and Lee A. Jackson, Alexander F. Prescott and John A. Bailey, Attorneys, Department of Justice, Washington, D. C., on the brief, for respondent.

Before VOGEL, BLACKMUN and RIDGE, Circuit Judges.

RIDGE, Circuit Judge.

In this case the Tax Court ruled that a subscription made and paid by a taxpayer as a "room endowment" to the building fund of a charitable institution admittedly having a tax-exempt status under Section 501(c) (3) of I.R.C.1954, 26 U.S.C.A. § 501(c) (3), was not a "gift" within the ambit of Section 170 (c) (2), I.R.C.1954, 26 U.S.C.A. § 170(c) (2), because it was made with a "motive" and "expectancy" by the donor "to secure room occupancy...

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