Thorne v. Commissioner
United States Tax Court
P, the trustee of a charitable foundation, deposited the entire corpus of the foundation in a Bahamian bank which had lost its business license.
Read the full summary
P, the trustee of a charitable foundation, deposited the entire corpus of the foundation in a Bahamian bank which had lost its business license. The foundation made donations to individuals, to organizations which were not public charities, and to foreign organizations without receiving advance approval from R of its grant-making procedures, without exercising expenditure responsibility as required by sec. 4945(h), I.R.C., and without investigating the bona fides of either the foreign bank or charitable organizations. In managing the foundation, P relied entirely upon the direction of his tax…
1Opinion of the Court
SCOTT, Judge:
These consolidated cases were assigned to Special Trial Judge Stanley J. Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Goldberg, Special Trial Judge:
Respondent determined that petitioner is liable for deficiencies in excise taxes, additions to tax, and penalties as…
2Cases cited13 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Roberts v. CommissionerUnited States Tax Court · 1974
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Rockwell v. CommissionerUnited States Tax Court · 1972
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Parks v. Comm'rUnited States Tax Court · 2015
- Thorne v. CommissionerUnited States Tax Court · 1992