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JULIA R. & ESTELLE L. FOUNDATION INC. v. C. I. R.

No. 519, Docket 78-4164.

598 F.2d 755 (1979)

JULIA R. & ESTELLE L. FOUNDATION INCORPORATED, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided May 7, 1979.

Attorney(s) appearing for the Case

Albert R. Mugel, Buffalo, N.Y. (Jaeckle, Fleischmann & Mugel, Buffalo, N.Y., of counsel), for appellant.

Michael J. Roach, Washington, D.C. (M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews and Gary R. Allen, Attys., Tax Div., Dept. of Justice, Washington, D.C., of counsel), for appellee.

Before OAKES, GURFEIN, and Van GRAAFEILAND, Circuit Judges.

Van GRAAFEILAND, Circuit Judge:

The issue in this case is whether a private foundation subject to the excise tax imposed by section 4940 of the Internal Revenue Code of 1954 (26 U.S.C. § 4940) must allocate its administrative expenses between its investment activities and its distribution activities and may deduct only the former in calculating its net investment income for excise tax purposes. Appellant, a private non-operating foundation, refused to make such...

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