United States Board of Tax Appeals January 7, 1932, Docket Nos. 31772, 41818 (Drexler v. Commissioner)

*80OPINION.

Lansdon:

The petitioner contends that the trust here involved is a charitable organization and that it is exempt from tax under section 231 of the Eevenue Act of 1926. The respondent has determined that it is taxable under section 219. Clearly the petitioner does not come within the provisions of section 231.