Polm Family Foundation v. United States

644 F.2d 406 (2011)

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Polm Family Foundation v. United States

United States Court of Appeals for the District of Columbia Circuit
644 F.2d 406 (2011)

Facts

The Polm Family Foundation (the foundation) (plaintiff) challenged a determination by the Internal Revenue Service (IRS) (defendant) that the foundation was not a public charity as defined in § 509(a)(3) of the Internal Revenue Code. According to the foundation’s articles of incorporation, it existed to conduct and support activities for the benefit of or to perform the functions of other organizations that supported, promoted, and/or performed public health and/or Christian objectives, including but not limited to Christian evangelism. The district court determined that the foundation did not qualify as a public charity and entered summary judgment in favor of the IRS. The foundation appealed.

Rule of Law

Issue

Holding and Reasoning (Randolph, J.)

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