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LARCHMONT FOUNDATION, INC. v. COMMISSIONER

Docket No. 9860-75.

43 T.C.M. 838 (1982)

T.C. Memo. 1982-145

Larchmont Foundation, Inc. and Paul R. Stout v. Commissioner.

United States Tax Court.

Filed March 23, 1982.

Attorney(s) appearing for the Case

Paul R. Stout, pro se, 150 N. Main St., Lombard, Ill. Carolyn A. Boyer, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

This case is now before us as a result of a remand by the Court of Appeals for the Seventh Circuit in which such court vacated the portion of our decision holding that the provisions of section 4945(b) of the Internal Revenue Code of 19541 imposing "second-tier taxes" on private foundations and their managers were invalid and unenforceable. On June 11, 1981, the circuit court directed us to...

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