T.C. Memo. 2002-300
UNITED STATES TAX COURT
CHRISTIE E. CUDDEBACK AND LUCILLE M.
CUDDEBACK MEMORIAL FUND, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5453-01X. Filed December 6, 2002.
David K. Hayes, for petitioner.
Robin W. Denick, for respondent.
MEMORANDUM OPINION
WHALEN, Judge: This is an action for declaratory
judgment, pursuant to section 7428(a)(1)(B), involving
respondent's determination with respect to the initial
classification of petitioner as a private foundation, as
defined by section 509(a). Unless stated otherwise, all
section references are to the Internal Revenue Code as in
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