Lapham Foundation, Inc. - Page 1

                                 T.C. Memo. 2002-293                                  

                               UNITED STATES TAX COURT                                

                       LAPHAM FOUNDATION, INC., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3881-01X.             Filed November 27, 2002.              

                    P is a nonprofit corporation described in sec.                    
               501(c)(3), I.R.C., and exempt from taxation under sec.                 
               501(a), I.R.C.  P’s articles of incorporation, as filed                
               in conjunction with its application for exempt status,                 
               provide that it is to operate exclusively for the                      
               benefit of the American Endowment Foundation, a                        
               publicly supported charitable organization.  The                       
               Commissioner determined that P was a private foundation                
               and not a supporting organization as defined in section                
               509(a)(3), I.R.C.                                                      
                    Held:  P is to be classified as a private                         
               foundation on account of failure to satisfy the                        
               integral part test of sec. 1.509(a)-4(i)(3), Income Tax                
               Nancy Ortmeyer Kuhn, for petitioner.                                   
               Helen F. Rogers, for respondent.                                       

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