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It concluded that this stuff had 'cost' and due to this fact 'foundation' to petitioner, since that they had been paid for from petitioner's own unrestricted funds wherein the money contributions had been deposited with out earmarking; as to the buildings transferred, the Court sustained the Commissioner on the ground that these transfers were not gifts and due to this fact the transferor's basis was not obtainable to petitioner. The values of the buildings acquired have been set up in a building account on the assets side and were credited to surplus. Under any such contract petitioner was obligated in the event of noncompliance to switch the building back to the group group or to repay the sum. Because in the Detroit Edison case 'The funds had been to the customer the worth of the service,' the Court concluded that 'it overtaxes imagination to regard the farmers and different clients who furnished these funds as makers both of donations or contributions to the corporate.' Since on this case there are neither customers nor payments for service, we might infer a unique purpose within the transactions between petitioner and the community groups.

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