Legal Opinion

Lapham Found., Inc. v. Comm'r

United States Tax Court

Decided November 27, 2002No. 3881-01XUnpublished

P is a nonprofit corporation described in sec. 501(c)(3), I.R.C., and exempt from taxation under sec. 501(a), I.R.C. P's articles of incorporation, as filed in conjunction with its application for exempt status, provide that it is to operate exclusively for the benefit of the American Endowment Foundation, a publicly supported charitable organization.

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P is a nonprofit corporation described in sec. 501(c)(3), I.R.C., and exempt from taxation under sec. 501(a), I.R.C. P's articles of incorporation, as filed in conjunction with its application for exempt status, provide that it is to operate exclusively for the benefit of the American Endowment Foundation, a publicly supported charitable organization. The Commissioner determined that P was a private foundation and not a supporting organization as defined in section 509(a)(3), I.R.C. Held: P is to be classified as a private foundation on account of failure to satisfy the integral part test of…

1Opinion of the Court

LAPHAM FOUNDATION, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lapham Found., Inc. v. Comm'r

No. 3881-01X

United States Tax Court

T.C. Memo 2002-293; 2002 Tax Ct. Memo LEXIS 315; 82 T.C.M. (CCH) 586;

November 27, 2002, Filed

Judgment entered for respondent.

P is a nonprofit corporation described in sec. 501(c)(3),

I.R.C., and exempt from taxation under sec. 501(a), I.R.C. P's

articles of incorporation, as filed in conjunction with its

application for exempt status, provide that it is to operate

exclusively for the benefit of the American Endowment

Foundation, a publicly supported…

2Cases cited5 opinions

  1. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  2. Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
  3. Cockerline Memorial Fund v. CommissionerUnited States Tax Court · 1986
  4. Nellie Callahan Scholarship Fund v. CommissionerUnited States Tax Court · 1980
  5. Quarrie v. CommissionerCourt of Appeals for the Seventh Circuit · 1979

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