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FOUNDATION OF HUMAN UNDERSTANDING v. COMMISSIONER

Docket No. 10431-83X.

88 T.C. 1341 (1987)

FOUNDATION OF HUMAN UNDERSTANDING, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 19, 1987.

Attorney(s) appearing for the Case

Joel R. Bryan, for the petitioner.

Joan R. Domike, for the respondent.

OPINION

GOFFE, Judge:

In 1965, the Internal Revenue Service issued a ruling letter which recognized that petitioner is exempt from Federal income tax as an organization described in section 501(c)(3).1 The Commissioner subsequently recognized petitioner as a nonprivate foundation because petitioner satisfied the requirements of a publicly supported organization described in sections...

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