§399
13 cases·13 cited
Statute Text — 26 U.S.C. §399
Statute text not available for this section.
13 Citing Cases
ot take Rev. Proc. 68-16, supra, to support the view that the caption transforms a narrow closing agreement to a broad, sweeping one. - 33 - broaden the scope ofthe closing agreement beyond what the parties intended.28 S_e_e 17A C.J.S., Contracts, sec. 399 (2011); c£ 11 Williston on Contracts, sec. 32:10 (4th ed. 1999) ("Even absent a true conflict, specific words will limit the meaning ofgeneral words ifit appears from the whole agreement that the parties' purpose was directed solely toward the
ion to devote the property to charitable purposes, the trust will not fail but the court will direct the application ofthe property to some charitable purpose which falls within the general charitable intention ofthe settlor. Restatement, Trusts 2d, sec. 399 (1959). The operation ofthe cy pres doctrine can be illustrated by the following example. A person bequeathed property in trust to establish a hospital in a particular town. Before the hospital could be built, a similar hospital was establis
ct the application of the property to some charitable purpose which falls within the general charitable intention of the settlor." Dunbar v. Board of Trs. of George W. Clayton College, 461 P.2d 28, 30 (Colo. 1969) (quoting 11 Restatement, Trusts 2d, sec. 399 (1959)). - 16 - prevents the parties from agreeing to extinguish the conservation easements in the event it becomes.impossible to carry out the purposes of the conservation easements. Rather, it is petitioners' contention that the cy pres do
ct the application of the property to some charitable purpose which falls within the general charitable intention of the settlor." Dunbar v. Board of Trs. of George W. Clayton College, 461 P.2d 28, 30 (Colo. 1969) (quoting 11 Restatement, Trusts 2d, sec. 399 (1959)). - 16 - prevents the parties from agreeing to extinguish the conservation easements in the event it becomes.impossible to carry out the purposes of the conservation easements. Rather, it is petitioners' contention that the cy pres do