Bilingual Montessori School of Paris v. Commissioner

75 T.C. 480 (1980)

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Bilingual Montessori School of Paris v. Commissioner

United States Tax Court
75 T.C. 480 (1980)

Facts

Bilingual Montessori School of Paris, Inc. (the corporation) (plaintiff) was a nonstock, nonprofit corporation organized under Delaware law that operated a private school in Paris, France. The school’s founder, Barbara Baylor Cole Porter, obtained her international Montessori diploma in Washington, D.C., where she founded a school that closed when she moved to Paris. Porter founded a new school in Paris and incorporated it in Delaware. The corporation conducted no activities and had no officers, directors, or employees in the United States. All contributions received by the corporation were used to cover expenses associated with the school in Paris. The commissioner of internal revenue (commissioner) (defendant) granted the corporation’s application for exemption from income taxation under § 501(c)(3) of the Internal Revenue Code (code) but determined that contributions to the corporation were not tax deductible because the corporation was not a domestic organization. The corporation sought a declaratory judgment that contributions to the corporation qualified as tax deductible. However, the commissioner argued that the corporation was nothing more than an agent or conduit for a foreign private school.

Rule of Law

Issue

Holding and Reasoning (Ekman, J.)

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