Thorne v. Commissioner
United States Tax Court
P, the trustee of a charitable foundation, deposited the entire corpus of the foundation in a Bahamian bank which had lost its business license.
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P, the trustee of a charitable foundation, deposited the entire corpus of the foundation in a Bahamian bank which had lost its business license. The foundation made donations to individuals, to organizations which were not public charities, and to foreign organizations without receiving advance approval from R of its grant-making procedures, without exercising expenditure responsibility as required by sec. 4945(h), I.R.C., and without investigating the bona fides of either the foreign bank or charitable organizations. In managing the foundation, P relied entirely upon the direction of his tax…
1Opinion of the Court
John E. Thorne, Petitioner v. Commissioner of Internal Revenue, Respondent; John E. Thorne, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Thorne v. Commissioner
Docket Nos. 15467-80, 29911-85
United States Tax Court
99 T.C. 67; 1992 U.S. Tax Ct. LEXIS 55; 99 T.C. No. 4;
July 20, 1992, Filed
Decisions will be entered under Rule 155.
P, the trustee of a charitable foundation, deposited the entire corpus of the foundation in a Bahamian bank which had lost its business license. The foundation made donations to individuals, to organizations which were not public charities, and to…
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Roberts v. CommissionerUnited States Tax Court · 1974
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Rockwell v. CommissionerUnited States Tax Court · 1972
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