German Soc. of Maryland, Inc. v. Commissioner
United States Tax Court
Petitioner, a tax-exempt private foundation, awarded scholarships without obtaining approval of its grant-making procedures as required by sec. 4945(g), I.R.C. 1954. Approval of these exact procedures was received and made retroactive to the date of application. Held, petitioner is liable for the initial excise tax imposed by sec. 4945(a)(1); provisions regarding correction of improper expenditures do not apply to the first-tier tax.
1Opinion of the Court
German Society of Maryland, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
German Soc. of Maryland, Inc. v. Commissioner
Docket No. 3512-80
United States Tax Court
80 T.C. 741; 1983 U.S. Tax Ct. LEXIS 96; 80 T.C. No. 35;
April 21, 1983, Filed
Decision will be entered for the respondent.
Petitioner, a tax-exempt private foundation, awarded scholarships without obtaining approval of its grant-making procedures as required by sec. 4945(g), I.R.C. 1954. Approval of these exact procedures was received and made retroactive to the date of application. Held, petitioner is liable for the…
2Cases cited3 opinions
- Adams v. CommissionerUnited States Tax Court · 1979
- Larchmont Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- German Soc. of Maryland, Inc. v. CommissionerUnited States Tax Court · 1983