Trinidad v. Sagrada Orden, 263 U.S. 578 (1924)

Trinidad v. Sagrada Orden de Predicadores de la


Provincia del Santisimo Rosario de Filipinas
No. 53


Submitted October 5, 1923
Decided January 14, 1924
263 U.S. 578

CERTIORARI TO THE SUPREME COURT
OF THE PHILIPPINE ISLANDS

Syllabus

The Income Tax Act of October 3, 1913, excepted any corporation

organized and operated exclusively for religious, charitable, . . . or educational purposes, no part of the net income of which inures to the benefit of any private stockholder or individual.

Held, that a corporation sole, organized, in the Philippines for those purposes and holding all its property therefor, was not taxable on income, used exclusively for those purposes and derived mainly from rents from its lands, interest from its money lent, and dividends on stocks of private corporations in which its funds were invested, and in small part from occasional sales of such stocks and from sales of wine and other articles, purchased and supplied for use in its churches, schools, and other agencies as an incident to its work. P. 581.

42 Phil.Rep. 397 affirmed.

Certiorari to a judgment of the Supreme Court of the Philippines affirming a judgment for the respondent in its action to recover money paid under protest as a tax on income.