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JOHN ALLAN LOVE CHARITABLE FOUNDATION v. U.S.

No. 80-1557C(3).

540 F.Supp. 238 (1982)

JOHN ALLAN LOVE CHARITABLE FOUNDATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Missouri, E. D.

April 9, 1982.

Attorney(s) appearing for the Case

Thomas E. Tooney, III, Clayton, Mo., for plaintiff.

James Crowe, Asst. U. S. Atty., St. Louis, Mo., G. Scott Nebergal, Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM

FILIPPINE, District Judge.

This is an action for refund of income taxes paid by The John Allan Love Personal Trust for the years 1975, 1976, and 1977. The action has been submitted upon stipulated facts. The primary issue is whether or not certain payments made by the Trust to the John Allan Love Charitable Foundation, and to other charities, were made "pursuant to the terms of" the Trust instrument, so as to entitle the Trust to charitable deductions...

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