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ROE FOUNDATION CHARITABLE TRUST v. COMMISSIONER

Docket No. 46959-86X.

58 T.C.M. 402 (1989)

T.C. Memo. 1989-566

Roe Foundation Charitable Trust, Stan A. Long, Trustee v. Commissioner.

United States Tax Court.

Filed October 19, 1989.

Attorney(s) appearing for the Case

Stan A. Long, pro se. Larry N. Johnson, for the respondent.

Memorandum Opinion

CLAPP, Judge:

The Roe Foundation Charitable Trust (Roe Foundation or petitioner) is a foundation described in section 501(c)(3) and exempt from taxation under section 501(a). Petitioner is a private foundation as defined in section 509(a).1 Petitioner brought an action under section 74282 for declaratory judgment that it is not a private foundation because it is an organization...

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