George F. Harding Museum v. United States

MEMORANDUM AND ORDER

MORAN, District Judge.

The Internal Revenue Service terminated plaintiffs status as a tax-exempt private foundation, as defined in the Internal Revenue Code, 26 U.S.C. § 501(c)(3), while simultaneously placing upon it a $30,000,-000 jeopardy assessment. Section 507(a)(2) directs the IRS to terminate a private foundation’s § 501(c)(3) status for wilful, repeated or flagrant acts giving rise to tax liability under chapter 42 of the Code, 26 U.S.C. § 4940 et seq. Plaintiff George F. Harding Museum (the Museum) moves here for an order to abate the jeopardy assessment. Pursuant…