Greene v. United States

MEMORANDUM DECISION & ORDER

PARKER, District Judge.

This matter, which is before this Court following remand from the United States Court of Appeals, involves the income tax consequences arising from the donation of futures contracts by Leonard Greene and Joyce Greene (collectively “the Greenes”) to the Institute for Socioeconomic Studies (“the Institute”), an exempt private operating foundation under 26 U.S.C. § 501(c)(3). See Greene v. United States, 79 F.3d 1348 (2d Cir.1996) (Greene II). The Greenes’ donations have been the subject of a.number of prior proceedings. See Greene v. United…