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 More than a century ago, the Court announced the caveat that is critical in this case: '[I]t has now become an established principle of American law that courts of chancery will sustain and protect . . . a gift . . . to public charitable uses, provided the same is consistent with local laws and public policy. . . .' 65 U. S. 501 (1861) (emphasis added). Soon after that, in 1877, the Court commented: 'A charitable use, where neither law nor public policy forbids, may be applied to almost any thing that tends to promote the well-doing and well-being of social man.' Ould v. Washington Hospital for Foundlings, 95 U. S. 303, 95 U. S. 311 (emphasis added). See also e.g., Jackson v. Phillips, 96 Mass. 539, 556 (1867). 


In 1891, in a restatement of the English law of charity [The draftsmen of the 1894 income tax law, which included the first charitable exemption provision, relied heavily on English concepts of taxation, and the list of exempt organizations appears to have been patterned upon English income tax statutes. See 26 Cong.Rec. 584-588, 6612-6615 (1894)] which has long been recognized as a leading authority ...

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