The U.S. Court of Appeals, Sixth Circuit, ruled on the classification of Lapham Foundation, Inc. as a private foundation rather than a supporting organization under section 509(a)(3) of the Internal Revenue Code. The court held that the foundation failed to meet the integral part test, which requires significant involvement in the operations of a publicly supported organization. The foundation's support to the American Endowment Foundation was not sufficient to ensure attentiveness, and the foundation was controlled by disqualified persons. The decision was entered for the respondent, Commissioner of the IRS.
documents/EFTA00598071.pdf
{}