Parks v. Comm'r
United States Tax Court
PF is a corporation exempt from income tax under I.R.C. sec. 501(c)(3) and classified as a private foundation under I.R.C. sec. 509(a). P is a foundation manager of PF as defined in I.R.C. sec. 4946(b). During its taxable years ended Nov. 30, 1997 through 2000, PF made cumulative expenditures of $639,073 to produce and broadcast 30- and 60-second radio messages. As a foundation manager, P agreed to the making of the expenditures.
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PF is a corporation exempt from income tax under I.R.C. sec. 501(c)(3) and classified as a private foundation under I.R.C. sec. 509(a). P is a foundation manager of PF as defined in I.R.C. sec. 4946(b). During its taxable years ended Nov. 30, 1997 through 2000, PF made cumulative expenditures of $639,073 to produce and broadcast 30- and 60-second radio messages. As a foundation manager, P agreed to the making of the expenditures. R determined that the foregoing expenditures were "attempts to influence legislation and/or the opinion of the general public" and therefore taxable expenditures,…
1Opinion of the Court
LOREN E. PARKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
PARKS FOUNDATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Parks v. Comm'r
Docket Nos. 7043-07, 7093-07.
United States Tax Court
145 T.C. 278; 2015 U.S. Tax Ct. LEXIS 43; 145 T.C. No. 12;
November 17, 2015, Filed
Decisions will be entered pursuant to Rule 155.
PF is a corporation exempt from income tax under I.R.C. sec. 501(c)(3) and classified as a private foundation under I.R.C. sec. 509(a). P is a foundation manager of PF as defined in I.R.C. sec. 4946(b). During its taxable years ended Nov. 30, 1997…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ward v. Rock Against RacismSupreme Court of the United States · 1989
- Rodriguez De Quijas v. Shearson/American Express, Inc.Supreme Court of the United States · 1989
- Citizens United v. Federal Election CommissionSupreme Court of the United States · 2010
- Speiser v. RandallSupreme Court of the United States · 1958
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