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THE LESAVOY FOUNDATION v. COMMISSIONER

Docket No. 51940.

25 T.C. 924 (1956)

THE LESAVOY FOUNDATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 31, 1956.

Attorney(s) appearing for the Case

William F. Snyder, Esq., and Clendon H. Lee, Esq., for the petitioner.

Stanley W. Herzfeld, Esq., for the respondent.

The respondent has determined deficiencies in income tax and additions to tax for delinquency and negligence pursuant to sections 291 (a) and 293 (a) of the Internal Revenue Code of 1939 against the petitioner for the calendar years 1946, 1947, 1948, and 1950. The tax and additions are in the total amount of $903,755.86. Petitioner claims to be exempt from income tax for the above taxable years by virtue of section 101 (6) of the Internal Revenue Code of 1939. The principal...

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