H. Fort Flowers Foundation, Inc. v. Commissioner
United States Tax Court
Petitioner, a charitable private foundation, had income in 1970, 1971, 1972, 1973, and 1974. None of this income was distributed for charitable purposes until 1975. Instead, petitioner on its books applied the income to restore its corpus which had been depleted by a large gift to Vanderbilt University in 1965. This treatment had been sanctioned by an auditing revenue agent in 1972. However, when it was challenged on a later audit, petitioner made an election under sec.…
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Petitioner, a charitable private foundation, had income in 1970, 1971, 1972, 1973, and 1974. None of this income was distributed for charitable purposes until 1975. Instead, petitioner on its books applied the income to restore its corpus which had been depleted by a large gift to Vanderbilt University in 1965. This treatment had been sanctioned by an auditing revenue agent in 1972. However, when it was challenged on a later audit, petitioner made an election under sec. 4942(h)(2), I.R.C. 1954, to have its 1975 qualifying distribution treated as made out of the earlier years' undistributed…
1Opinion of the Court
H. Fort Flowers Foundation, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
H. Fort Flowers Foundation, Inc. v. Commissioner
Docket No. 2982-77
United States Tax Court
72 T.C. 399; 1979 U.S. Tax Ct. LEXIS 111;
June 4, 1979, Filed
Decision will be entered under Rule 155.
Petitioner, a charitable private foundation, had income in 1970, 1971, 1972, 1973, and 1974. None of this income was distributed for charitable purposes until 1975. Instead, petitioner on its books applied the income to restore its corpus which had been depleted by a large gift to Vanderbilt University in 1965. This…
2Cases cited6 opinions
- Darling v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1931
- Adams v. CommissionerUnited States Tax Court · 1979
- Martin's Auto Trimming, Inc., a Corporation v. Robert A. Riddell, Director of Internal Revenue Service and United States of AmericaCourt of Appeals for the Ninth Circuit · 1960
- H. Fort Flowers Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Henry v. BurnetCourt of Appeals for the D.C. Circuit · 1931
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