MOSE & GARRISON SISKIN MEMORIAL FOUNDATION v. U.S.

No. 85-5075.

790 F.2d 480 (1986)

MOSE AND GARRISON SISKIN MEMORIAL FOUNDATION, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 8, 1986.


Attorney(s) appearing for the Case

William L. Taylor, Jr. (argued), Spears, Moore, Rebman & Williams, Chattanooga, Tenn., Mark Allen Ramsey, for plaintiff-appellant.

Raymond W. Hepper (argued), John W. Gill, U.S. Atty., Chattanooga, Tenn., Robert E. Rice, Tax Div., Dept. of Justice, Washington, D.C., Michael L. Paup, Glenn L. Archer, Jr., Robert A. Bernstein, for defendant-appellee.

Before ENGEL, KENNEDY and RYAN, Circuit Judges.


CORNELIA G. KENNEDY, Circuit Judge.

This appeal presents the question whether the Internal Revenue Code's ("I.R.C.") "unrelated business income" provisions apply to income that a charitable organization derives by withdrawing the accumulated cash value of life insurance policies that the charitable organization owns and reinvesting the proceeds in marketable securities and other income paying investments. The District Court held that since the proceeds from the withdrawals...

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