Name/Title
Letter Dec 4,1952 to IRS regarding tax exempt application from Robert McLeod JacksonEntry/Object ID
001697Tags
Robert McLeod JacksonScope and Content
December 4, 1952.
Commissioner of Internal Revenue
U. S. Treasury Department
Washington 25, D. C.
Attention: Income Tax Division
Re: <u>The William Bull and Sarah Wells Family Association, Inc.</u>
Dear Sir:
I am desirous of knowing whether the above named Association, a New York membership corporation without capital stock, whose principal property is a historical house built in 1722 and the farmland surrounding it amounting to something over 100 acres, can qualify so that contributions to the Association from its members will be tax exempt gifts to the contributors. The Association does no business and makes no money. It rents its farmland for $225.00 a year, but neither that rental nor interest on the Association's endowment by any means pays its expenses of maintenance of the house.
In the event of the Association's dissolution, this property would be disposed of in accordance with a two-thirds vote of the Board of Managers of the Association subject to ratification by a majority vote of the members of the Association voting.
I see that under Section 101(6) exemption is granted to certain classes of organizations, not, however, mentioning historical associations. Is this Section construed to exempt historical organizations, or is there some other provision of law which is applicable to historical associations?
I enclose herewith a copy of a notice of the 1952 annual meeting of the Association which was sent out to its members and which contains the Treasurer's report for the period from July 1, 1951 to July 10, 1952. If there is any further information you wish about the corporation, I will of course be glad to send it to you.
Thanking you in advance for the courtesy of a reply, I remain
Yours very truly,
[Signature]
Robert McLeod Jackson
Secretary
RMJ:ba