CROSBY VALVE & GAGE COMPANY v. C. I. R.

No. 6872.

380 F.2d 146 (1967)

CROSBY VALVE & GAGE COMPANY (Formerly Crosby Steam Gage & Valve Company), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals First Circuit.

June 21, 1967.


Attorney(s) appearing for the Case

Jack H. Calechman, Boston, Mass., with whom Alford P. Rudnick and Peter D. Gens, Boston, Mass., were on brief, for petitioner.

Albert J. Beveridge, III, Atty., Department of Justice, with whom Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and Harry Baum, Attys., Department of Justice, were on brief, for respondent.

Before ALDRICH, Chief Judge, McENTEE and COFFIN, Circuit Judges.


COFFIN, Circuit Judge.

Is a business corporation, wholly owned by a charitable foundation, entitled to a charitable deduction for property (in this case equity in bonds) turned over without consideration to its parent? This is the issue posed by this petition to review a decision of the Tax Court.

The Tax Court held that the transfers to the foundation were not deductible. It placed primary emphasis on its syllogism that (1) "charitable contribution" is synonymous...

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