Lapham Found., Inc. v. Comm'r
United States Tax Court
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
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
- Cockerline Memorial Fund v. CommissionerUnited States Tax Court · 1986
- Nellie Callahan Scholarship Fund v. CommissionerUnited States Tax Court · 1980
- Quarrie v. CommissionerCourt of Appeals for the Seventh Circuit · 1979