Texas Learning Technology Group v. Commissioner
United States Tax Court
P, an exempt organization under sec. 501(c)(3), I.R.C., that was established pursuant to interlocal agreements with 11 Texas public school districts to formulate, develop, and administer programs on behalf of group member school districts to assist in the improvement of student learning and to further implement the purposes and objectives of the Texas Education Code, sought classification as a nonprivate foundation under sec. 509(a)(1), I.R.C., on the ground that it was a…
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P, an exempt organization under sec. 501(c)(3), I.R.C., that was established pursuant to interlocal agreements with 11 Texas public school districts to formulate, develop, and administer programs on behalf of group member school districts to assist in the improvement of student learning and to further implement the purposes and objectives of the Texas Education Code, sought classification as a nonprivate foundation under sec. 509(a)(1), I.R.C., on the ground that it was a political subdivision of a State as described in sec. 170(b)(1)(A)(v) and (c)( 1), I.R.C. Held, that P is not a political…
1Opinion of the Court
OPINION
TANNENWALD, Judge:
Respondent denied petitioner’s application for recognition as a nonprivate foundation within the meaning of section 509(a)(1).1 The issue for decision is whether petitioner qualifies as a nonprivate foundation under section 509(a)(1) because it is a political subdivision of a State as described in section 170(b)(l)(A)(v) and (c)(1).2
This case was submitted under Rule 122. The parties have filed a joint stipulation as to the completeness and genuineness of the administrative record, and the evidenti-ary facts and representations contained in the administrative record…
2Cases cited13 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- United States v. Cambridge Loan & Building Co.Supreme Court of the United States · 1928
- Brown v. United StatesCourt of Appeals for the Fifth Circuit · 1989
- Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
- Allied Fidelity Corporation, F/k/a, William E. Roe, Allied Agents, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1978
8 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Uniband, Inc. v. CommissionerUnited States Tax Court · 2013
- Bear v. CommissionerUnited States Tax Court · 1992
- Texas Learning Technology Group v. CommissionerUnited States Tax Court · 1991
- Uniband, Inc. v. CommissionerUnited States Tax Court · 2013