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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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