Trustees for the Home for Aged Women v. United States

1986 U.S. Dist. LEXIS 28089 (1986)

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Trustees for the Home for Aged Women v. United States

United States District Court for the District of Massachusetts
1986 U.S. Dist. LEXIS 28089 (1986)

Facts

The Home for Aged Women (the home) (plaintiff) was incorporated in 1869 with an endowment fund donated by the public. Upon admission to the home, residents paid an administrative fee and assigned their property, as well as social-security and private-pension benefits, to the home in lieu of paying periodic fees. The home also encouraged attorneys to mention possible bequests to the home to their estate-planning clients. In 1972, the Internal Revenue Service (IRS) (defendant) designated the home as a tax-exempt organization under Internal Revenue Code § 501(c)(3) and determined under § 509(a) that the home was a private foundation subject to the excise-tax requirements of § 4940. The home paid excise taxes assessed by the IRS for 1971 through 1977 while disputing the private-foundation designation. During the relevant period, at least 10 percent of the home’s total support was derived from public contributions. The home sought a refund of the excise taxes.

Rule of Law

Issue

Holding and Reasoning (Freedman, J.)

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