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Bartels Trust v. United States
United States Court of Appeals for the Second Circuit
209 F.3d 147 (2000)
The Henry E. & Nancy Horton Bartels Trust for the Benefit of the University of New Haven (the trust) (plaintiff) was a tax-exempt organization established to support the University of New Haven (UNH). The trust borrowed money to buy securities on margin. After paying taxes on the income from those securities, the trust filed a petition with the Internal Revenue Service (IRS) (defendant) for a tax refund. The IRS denied the petition. The trust appealed in federal district court. The district court affirmed the denial, granting the IRS summary judgment. The trust appealed.
Rule of Law
Holding and Reasoning (Wexler, J.)
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