FINDINGS OF FACT AND CONCLUSIONS OF LAW
JACK M. GORDON, District Judge.
An excise tax on the net investment income of private foundations is imposed under the provisions of 26 U.S.C. § 4940. In 1974, plaintiff, the Zemurray Foundation, sold its undivided one-half interest in approximately 12,746 acres of timber land in Tangipahoa Parish, Louisiana. Subsequent to and as a result of that sale, the Commissioner of Internal Revenue assessed an excise tax...
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