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
Regs.
Nancy Ortmeyer Kuhn, for petitioner.
Helen F. Rogers, for respondent.
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