Legal Opinion

"Miss Elizabeth" D. Leckie Scholarship Fund v. Commissioner

United States Tax Court

Decided July 30, 1986No. Docket No. 5028-84XPublished

P, a "sec. 509(a) private foundation," seeks a declaratory judgment from R's final ruling denying it "operating foundation" status, as defined in sec. 4942(j)(3), I.R.C. 1954. P is already a charitable trust exempt from Federal income taxation under sec. 501(c)(3), I.R.C. 1954, but would gain additional benefit from "operating foundation" status, including an exemption from excise tax under sec. 4942, I.R.C. 1954. See secs. 4942(a) and 4942(a)(1), I.R.C. 1954. P anticipated…

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P, a "sec. 509(a) private foundation," seeks a declaratory judgment from R's final ruling denying it "operating foundation" status, as defined in sec. 4942(j)(3), I.R.C. 1954. P is already a charitable trust exempt from Federal income taxation under sec. 501(c)(3), I.R.C. 1954, but would gain additional benefit from "operating foundation" status, including an exemption from excise tax under sec. 4942, I.R.C. 1954. See secs. 4942(a) and 4942(a)(1), I.R.C. 1954. P anticipated $ 6,600 annual interest income, $ 6,000 of which was to be applied to scholarships and $ 600 to administrative expenses.…

1Opinion of the Court

The "Miss Elizabeth" D. Leckie Scholarship Fund, Petitioner v. Commissioner of Internal Revenue, Respondent

"Miss Elizabeth" D. Leckie Scholarship Fund v. Commissioner

Docket No. 5028-84X

United States Tax Court

87 T.C. 251; 1986 U.S. Tax Ct. LEXIS 71; 87 T.C. No. 16;

July 30, 1986, Filed

Decision will be entered for the petitioner.

P, a "sec. 509(a) private foundation," seeks a declaratory judgment from R's final ruling denying it "operating foundation" status, as defined in sec. 4942(j)(3), I.R.C. 1954. P is already a charitable trust exempt from Federal income taxation under sec. 501(c)(3),…

2Cases cited4 opinions

  1. Huntsberry v. CommissionerUnited States Tax Court · 1984
  2. Garrison v. CommissionerUnited States Tax Court · 1986
  3. "Miss Elizabeth" D. Leckie Scholarship Fund v. CommissionerUnited States Tax Court · 1986
  4. Trust Under Will of Mabury v. CommissionerUnited States Tax Court · 1983

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