Hans S. Mannheimer Charitable Trust v. Comm'r of Internal Revenue

3 Citing cases

  1. Thorne v. Commissioner of Internal Revenue

    99 T.C. 67 (U.S.T.C. 1992)   Cited 1 times

    Congress enacted subchapter A of chapter 42 in an effort "to put an end, as far as it reasonably could, to the abuses and potential abuses associated with private foundations." Mannheimer Charitable Trust v. Commissioner, 93 T.C. 35, 39 (1989). In general, section 4944 (a)(1) imposes an excise tax on each investment which jeopardizes the exempt purposes of a private foundation.

  2. Thorne v. Comm'r of Internal Revenue

    99 T.C. 67 (U.S.T.C. 1992)

    Congress enacted subchapter A of chapter 42, in an effort “to put an end, as far as it reasonably could, to the abuses and potential abuses associated with private foundations.” Mannheimer Charitable Trust v. Commissioner, 93 T.C. 35, 39 (1989). In general, section 4944(a)(1) imposes an excise tax on each investment which jeopardizes the exempt purposes of a private foundation.

  3. Autrey v. U.S.

    889 F.2d 973 (11th Cir. 1989)   Cited 13 times
    Holding under similar circumstances that the district court lacked jurisdiction to consider a challenge to a § 6700 penalty where the person assessed had not paid fifteen percent of the penalty to the IRS

    Discussing another provision of the Internal Revenue Code aimed at curbing abuse, Judge Raum observed that "Congress was obviously fed up with widespread abusive practices." Hans S. Mannheimer Charitable Trust v. Commissioner, 93 T.C. 35 (1989). We believe the section 6700 and 6701 penalties reflect a similar congressional intolerance of grossly abusive practices.