KUPER v. COMMISSIONER OF INTERNAL REVENUE

No. 14749.

332 F.2d 562 (1964)

Alan B. KUPER and Virginia A. Kuper, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided June 9, 1964.


Attorney(s) appearing for the Case

Martin D. Cohen, Newark, N. J. (Cohen, Rosenbaum & Scher, Newark, N. J., on the brief), for petitioners.

Morton K. Rothschild, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Attorneys, Department of Justice, Washington, D. C., on the brief), for respondent.

Before BIGGS, Chief Judge, HASTIE, Circuit Judge, and KIRKPATRICK, District Judge.


KIRKPATRICK, District Judge.

This is a petition to review a decision of the Tax Court holding that the taxpayers are not entitled to a deduction of a donation to the League of Women Voters of Millburn, New Jersey, as a charitable contribution within the meaning of Section 170(a) (1) and (c) (2) of the Internal Revenue Code of 1954. More narrowly stated, the issue is whether the record supports the finding of the Tax Court that a substantial part of the activities...

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