GEORGE F. HARDING MUSEUM v. U.S.

No. 86 C 2003.

674 F.Supp. 1323 (1987)

GEORGE F. HARDING MUSEUM, Plaintiff, v. The UNITED STATES of America, Defendant.

United States District Court, N.D. Illinois, E.D.

December 4, 1987.


Attorney(s) appearing for the Case

Roger J. McFadden, Jeffrey B. Lieberman, Schuyler, Roche & Zwirner, Chicago, Ill., for plaintiff.

M. Ellen Carpenter, Tax Div., U.S. Dept. of Justice, Washington, D.C., Joseph Duffy, Acting U.S. Atty., James P. White, Asst. U.S. Atty., Chicago, Ill., for defendant.


MEMORANDUM AND ORDER

MORAN, District Judge.

The Internal Revenue Service terminated plaintiff's status as a tax-exempt private foundation, as defined in the Internal Revenue Code, 26 U.S.C. § 501(c)(3), while simultaneously placing upon it a $30,000,000 jeopardy assessment. Section 507(a)(2) directs the IRS to terminate a private foundation's § 501(c)(3) status for wilful, repeated or flagrant acts giving rise to tax liability under chapter 42...

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