Gladstone Foundation v. Commissioner
United States Tax Court
Respondent by letter to petitioner proposed to revoke its nonprivate foundation status. Twenty-nine days later, petitioner submitted a written protest to respondent appealing the proposed revocation. After the lapse of more than 900 days from that submission and the completion of protest and appeals procedures, no final adverse determination letter had been sent.
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Respondent by letter to petitioner proposed to revoke its nonprivate foundation status. Twenty-nine days later, petitioner submitted a written protest to respondent appealing the proposed revocation. After the lapse of more than 900 days from that submission and the completion of protest and appeals procedures, no final adverse determination letter had been sent. Petitioner filed a declaratory judgment action under sec. 7428, I.R.C. 1954. Held, petitioner is an organization described in sec. 7428(a)(1) and entitled to bring an action under sec. 7428(a)(2) because respondent has failed to make…
1Opinion of the Court
J. David Gladstone Foundation, Richard S. Brawerman, Richard D. Jones, and David Orgell, Trustees, Petitioner v. Commissioner of Internal Revenue, Respondent
Gladstone Foundation v. Commissioner
Docket No. 2964-80X
United States Tax Court
77 T.C. 221; 1981 U.S. Tax Ct. LEXIS 86;
August 6, 1981, Filed
Respondent by letter to petitioner proposed to revoke its nonprivate foundation status. Twenty-nine days later, petitioner submitted a written protest to respondent appealing the proposed revocation. After the lapse of more than 900 days from that submission and the completion of protest and appeals…
Also in this document: Concurrence; Dissent · Featherston; Dissent · Chabot.
2Cases cited33 opinions
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Alexander v. "Americans United" Inc.Supreme Court of the United States · 1974
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- Smith v. Illinois Bell Telephone Co.Supreme Court of the United States · 1926
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