Legal Opinion

Quarrie Charitable Fund v. Commissioner

United States Tax Court

Decided May 8, 1978No. Docket No. 6837-77XPublished

Petitioner is an organization described in sec. 501(c)(3), I.R.C. 1954. Its trustee has authority to substitute new charitable beneficiaries for the named beneficiaries if the trustee determines that the original charitable uses have become "unnecessary, undesirable, impracticable, impossible or no longer adapted to the needs of the public."

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Petitioner is an organization described in sec. 501(c)(3), I.R.C. 1954. Its trustee has authority to substitute new charitable beneficiaries for the named beneficiaries if the trustee determines that the original charitable uses have become "unnecessary, undesirable, impracticable, impossible or no longer adapted to the needs of the public." Held, petitioner is a private foundation, not an organization described in sec. 509(a)(3), I.R.C. 1954, because the trustee's power of substitution is not conditioned upon an event which is beyond its control as required by the organizational test, sec.…

1Opinion of the Court

William F., Mable E., and Margaret K. Quarrie Charitable Fund, The Northern Trust Company, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent

Quarrie Charitable Fund v. Commissioner

Docket No. 6837-77X

United States Tax Court

70 T.C. 182; 1978 U.S. Tax Ct. LEXIS 126;

May 8, 1978, Filed

Decision will be entered for the respondent.

Petitioner is an organization described in sec. 501(c)(3), I.R.C. 1954. Its trustee has authority to substitute new charitable beneficiaries for the named beneficiaries if the trustee determines that the original charitable uses have become "unnecessary,…

2Cases cited7 opinions

  1. Key Buick Co. v. CommissionerUnited States Tax Court · 1977
  2. Mason v. Bloomington Library Ass'nIllinois Supreme Court · 1908
  3. Estate of William Zentmayer, Deceased, the First Pennsylvania Banking and Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1964
  4. Board of Education v. City of RockfordIllinois Supreme Court · 1939
  5. Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978

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