Legal Opinion
Beneficial Foundation, Inc. v. United States
United States Court of Claims
Decided August 9, 1985No. 159-79TPublishedCited by 7 opinions
1Opinion of the Court
OPINION
KOZINSKI, Chief Judge.
Plaintiff, an employer-related private foundation, challenges the Commissioner’s denial of a ruling that its program of providing educational grants to children of employees is exempt from excise tax under 26 U.S.C. § 4945(g) (1982).
Facts
Plaintiff is a private, non-profit charitable and educational organization exempt from taxation under 26 U.S.C. § 501(c)(3). Since its inception, plaintiff has derived its financial support in part through contributions from Beneficial Corporation and its subsidiaries (the “Beneficial Companies”), and their officers and…
2Cases cited14 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- The Lesavoy Foundation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
9 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Tobler v. DerwinskiUnited States Court of Appeals for Veterans Claims · 1991
- Disabled American Veterans v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Estate of Rapp v. CommissionerCourt of Appeals for the Ninth Circuit · 1998
- Travelers Insurance v. United StatesUnited States Court of Federal Claims · 1996
2 more not listed; retrieve them via the Exa API.