Collins v. Commissioner
United States Tax Court
In 1968 T, a physician, established a charitable foundation to which he, the sole contributor, donated some cash and the building in which he maintained his offices. The foundation thereupon leased the building to T. The foundation was associated with the preparation of two pamphlets on "traits" and "attitudes," the subject of its alleged charitable purpose.
Read the full summary
In 1968 T, a physician, established a charitable foundation to which he, the sole contributor, donated some cash and the building in which he maintained his offices. The foundation thereupon leased the building to T. The foundation was associated with the preparation of two pamphlets on "traits" and "attitudes," the subject of its alleged charitable purpose. Held, the foundation did not receive "a substantial part of its support * * * from direct or indirect contributions from the general public" as required by sec. 170(b)(1) (A)(vi), I.R.C. 1954, as a condition for T's additional charitable…
1Opinion of the Court
OPINION
Raum, Judge:
The threshold issue presented concerns whether the Government complied with the procedural dictates of section 7605 (b), which provides as follows:
SEC. 7605. TIME AND PLACE OF EXAMINATION.(b) Rbstkictions on Examination of Taxpayer. — No taxpayer shall be subjected to unnecessary examination or investigations, and only one inspection of a taxpayer’s boobs of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary or his delegate, after investigation, notifies the taxpayer in writing that an additional inspection is…
2Cases cited18 opinions
- United States v. PowellSupreme Court of the United States · 1964
- Cataldo v. CommissionerUnited States Tax Court · 1973
- Royal G. Bouschor v. United StatesCourt of Appeals for the Eighth Circuit · 1963
- Cleveland Trust Co. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Luhring v. GlotzbachCourt of Appeals for the Fourth Circuit · 1962
13 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Kolom v. Comm'rUnited States Tax Court · 1978
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
- Schwager v. CommissionerUnited States Tax Court · 1975
- Casanova Co. v. CommissionerUnited States Tax Court · 1986
39 more not listed; retrieve them via the Exa API.