Mannheimer Charitable Trust v. Commissioner
United States Tax Court
Petitioner, a private foundation, made grants to two other private foundations, all three of which had been established by the same person to promote his interest and concern about animals and nonhuman primates. Some of the same officers and trustees held similar positions in all three foundations.
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Petitioner, a private foundation, made grants to two other private foundations, all three of which had been established by the same person to promote his interest and concern about animals and nonhuman primates. Some of the same officers and trustees held similar positions in all three foundations. Held, on the facts of this case, petitioner is subject to the 10 percent excise tax on "taxable expenditures" imposed by sec. 4945(a)(1) of the Internal Revenue Code, since its contributions to the other two foundations during 1981-1983 were "taxable expenditures" within sec. 4945(d)(4), by reason…
1Opinion of the Court
Hans S. Mannheimer Charitable Trust, First Fidelity Bank, N.A., Trustee, Formerly First National State Bank of New Jersey, Petitioner v. Commissioner of Internal Revenue, Respondent
Mannheimer Charitable Trust v. Commissioner
Docket No. 44909-86
United States Tax Court
93 T.C. 35; 1989 U.S. Tax Ct. LEXIS 101; 93 T.C. No. 5;
July 12, 1989July 12, 1989, Filed
Decision will be entered for the respondent.
Petitioner, a private foundation, made grants to two other private foundations, all three of which had been established by the same person to promote his interest and concern about animals and nonhuman…
2Cases cited12 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Rev. Donald L. Jackson v. The Statler FoundationCourt of Appeals for the Second Circuit · 1974
- Davenport v. CommissionerUnited States Tax Court · 1967
- Quick Trust v. CommissionerUnited States Tax Court · 1970
- Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
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