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NOTES 929 Tax Lawyer, Vol. 56, No. 4 NOTE THE DIFFICULTIES OF ESTABLISHING A SUPPORTING ORGANIZATION WHEN MAKING CHARITABLE CONTRIBUTIONS TO A DONOR-ADVISED FUND PROGRAM: LAPHAM FOUNDATION INC. V. COMMISSIONER In Lapham Foundation Inc. v. Commissioner,1 the Tax Court held that a foundation making charitable grants to a donor-advised fund program was not a private foundation because it failed to meet the criteria for a supporting organizattio delineated in section 509(a)(3)(B).2 The court...

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