Roe Foundation Charitable Trust v. Commissioner
United States Tax Court
T.C. Memo. 1989-566 (1989)
- Written by Daniel Clark, JD
Facts
Raymond Sawyer and Evelyn Sawyer established the Roe Foundation Charitable Trust (foundation) (plaintiff), a § 501 exempt organization under the Internal Revenue Code (code). The trust documents provided that one of the foundation’s trustees was to be the president-elect of the Washington Community Action Agencies (WCAA). The WCAA president had one of four votes with respect to the foundation’s major operational decisions. The WCAA was a publicly supported organization under § 509 of the code. The WCAA was a consortium of state-agency directors that supported local charities serving needy, elderly people. The foundation’s trust documents stated that the trust was intended to serve poor or distressed elderly people and that the trust would provide funding based on, in part, referrals from the WCAA. The trust also listed Washington State as one of the trust’s beneficiaries. The foundation applied to the Internal Revenue Service (IRS) (defendant) for status as a supporting organization under § 509(a)(3) of the code. The IRS denied status to the foundation, and the foundation filed a petition challenging the IRS in the United States Tax Court.
Rule of Law
Issue
Holding and Reasoning (Clapp, J.)
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