Legal Opinion
Change-All Souls Housing Corp. v. United States
United States Court of Claims
Decided February 10, 1982No. 56-79PublishedCited by 16 opinions
1Opinion of the CourtFriedman, Chief Judge
The issue in this case is whether the plaintiff is a private foundation under section 509(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 509(a) (1976). The plaintiff seeks a declaratory judgment under 26 U.S.C. § 7428 that it is not such a foundation. We agree.
I
Before discussing the facts of this case, it is helpful to describe briefly the provisions of the Internal Revenue Code governing the determination whether a tax-exempt organization (which the plaintiff is) is or is not a private foundation.
The effect upon a tax-exempt organization of being a private foundation, as defined by…
2Cases cited6 opinions
- United States v. L. A. Tucker Truck Lines, Inc.Supreme Court of the United States · 1952
- Elisian Guild, Inc. v. United StatesCourt of Appeals for the First Circuit · 1969
- Warren M. Goodspeed Scholarship Fund, Baybank Merchants, N.A. v. CommissionerUnited States Tax Court · 1978
- Quarrie Charitable Fund v. CommissionerUnited States Tax Court · 1978
- Nellie Callahan Scholarship Fund v. CommissionerUnited States Tax Court · 1980
1 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- The Church of the New Testament, Its Members and Friends, Plaintiffs v. United StatesCourt of Appeals for the Ninth Circuit · 1986
- Joe Aulston and Lola Aulston v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Church of the Visible Intelligence that Governs Universe v. United StatesUnited States Court of Claims · 1983
- Change-All Souls Housing Corp. v. United StatesUnited States Court of Claims · 1982
- McManus v. CommissionerUnited States Tax Court · 1989
11 more not listed; retrieve them via the Exa API.