Legal Opinion
St. John's Orphanage, Inc. v. United States
United States Court of Claims
Decided February 16, 1989No. 188-87TPublishedCited by 5 opinions
1Opinion of the Court
OPINION
FUTEY, Judge.
St. John’s Orphanage, Inc., d/b/a Knoxville Children’s Foundation, Inc., a Tennessee corporation, brings this petition for declaratory judgment pursuant to 26 U.S.C. § 7428, challenging the Internal Revenue Service classification of the organization as a tax-exempt private foundation. Plaintiff contends that the organization qualifies as a tax-exempt nonprivate foundation pursuant to § 509(a)(1) of the Internal Revenue Code of 1954. For the reasons stated in this opinion plaintiff’s petition is denied.
Factual Background
The Church Orphanage of Knoxville was chartered in…
2Cases cited5 opinions
- Church of the Visible Intelligence that Governs Universe v. United StatesUnited States Court of Claims · 1983
- Incorporated Trustees of the Gospel Worker Society v. United StatesDistrict Court, District of Columbia · 1981
- Change-All Souls Housing Corp. v. United StatesUnited States Court of Claims · 1982
- Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
- Incorporated Trustees of Gospel Worker Society v. United StatesCourt of Appeals for the D.C. Circuit · 1981
3Cited by5 opinions
- New Dynamics Foundation v. United StatesUnited States Court of Federal Claims · 2006
- McLennan v. United StatesUnited States Court of Claims · 1991
- Church of Spiritual Technology v. United StatesUnited States Court of Claims · 1989
- Educational Assistance Foundation for the Descendants of Hungarian Immigrants in the Performing Arts, Inc. v. Commissioner of Internal RevenueDistrict Court, District of Columbia · 2015
- Kelsey v. RayDistrict of Columbia Court of Appeals · 1999