United States Sixth Circuit

A tax court's judgment, classifying plaintiff as a private foundation under 26 U.S.C. section 509(a)(3), is affirmed where plaintiff did not meet the "integral part" test set forth in 26 CFR. section 1.509(a)-4(i)(3).

Appellate Information

• Decided 11/18/2004
• Published 11/18/2004

Judges

• DAUGHTREY, Circuit Judge., Before:  DAUGHTREY and SUTTON, Circuit Judges;  COOK, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• ARGUED:James C. Thomas III, Husch & Eppenberger, Kansas City, Missouri, for Appellant. Francesca Ugolini, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF:James C. Thomas III, Husch & Eppenberger, Kansas City, Missouri, for Appellant. Francesca Ugolini, Kenneth L. Greene, United States Department of Justice, Washington, D.C., for Appellee.