Evening journal., 1922-04-13
WOODLAWN
CO. IS EXEMPT
Society of Natural History
Does Not Have to Pay
Income Tax
TOWNSEND GIVES
THREE OPINIONS

Opinions have been received by
State Tax Commissioner NJ. Howard
Jester from Attorney General Town
send holding that the woodlawn
Trustees. Inc. being organized and
existing for charitable purposes. are
exempt from taxation under the
Act TO Provide Revenue for School
Purposes; that the Society OF
Natural History OF Delaware. under
the facts in hand at this time. is eX-
empt from taxation under the same
act; and that persons convicted OF
felony. n a resident OF this State
during any portion of the last six
months OF 1921, are subject to taxa
ton:
The opinions follow:
you have asked for my opinion
as TO whether or not Woodlawn
Trustees. Inc. r. subject TO taxation
under the provisions OF Chapter 3.
Volume 80. Delaware Laws being
An Act TO Provide Revenue for
School Purposes
"The information upon which I
am TO base my opinion consists OF a
copy OF the charter OF said corpora
ton and OF a letter from the secre-
tary and Treasurer thereof. From
the charter II clearly appears that
the corporation was orgapized for
charitable purposes. From the let
ter II appears.
Il. That the corporation was or
ganized for philanthropic purposes
+ 20. That the corporation simply
holds and manages real estate for
phiianthropic purposes.
%. That the corporation has nc
capital stock.
"a. That the income and capita
are 10 be used for philanthropic pur-
poses.
"5. That no part OF the net earn.
ings Of the corporation inures 20 the
benefit Of any private stockholdei
or individual.
"Under the above statement o.
facts and assuming that there arr
none OF contrary import, I am o
visions OF paragraph four, sectioi
opinion that the above corporation 8
exempt from taxation under the pro
Q OF the above mentioned Act"
ION Saturday last you asked m
for an opinion as 10 whether or no
the Society Of Natural History o
Delaware is subject to taxation unde
the provisions OF Chapter 3. Volum
80. Delaware Laws. being An Ac
. to Provide Revenue for School Pur
+ poses. You left with me lette
from said society from which lette
CLEAN the following:
Il. The society was incorporate
/ for the cultivation OF nature
! sciences.
"2. 1t Is run practically on men
] bership dues.
3 80. It's lectures are open 20 n
4 public for educational purposes.
Under the above statement
e facts am OF opinion that the 81
= ciety Is exempt from taxation b.
n cause OF It's being a corporation o
ganized for scientific and educ
i tional purposes as contemplated
}. paragraph 4. section 0. OF the abo'
y entitled act.
9 'Of course there might be 9TH
4 facts not brought TO my attentiC
10 ] NnlNn NNAAA lAhlt Ant r0iANAg VIII
- out the protection OF said section
8 You have asked for my opiniC
as TO whether or not a person WI
has been convicted OF a felony
r subject TO the payment OF incon
e taxes. In reply 1 will advise you
r follows:
r IAN Act entitled An Act 70 Pr,
3 vide Revenue for School Purposel
8 being Chapter .. Volume 80. Deli
ware Laws, at Section 1, defines n
g word taxable TO mean a natur
o person, twenty-one years Of age
- over who is citizen or resident
A the State OF Delaware. A persC
I who has been convicted OF certa
Il felonies is not citizen in the SEN
= that he Is entitled 10 the right
! franchise but II such person was
n resident OF the State OF Delawai
= during any portion OF the last s
- months OF the year 1921, he is SUI
\, ject 10 the payment OF the filing Z,
and income tax under the abov
quoted law.
Yours very truly,
SYLVESTER d. TOWNSEND, ]
"Affnrnav rororafu