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MANNHEIMER TRUST v. COMMISSIONER

Docket No. 44909-86.

93 T.C. 35 (1989)

HANS S. MANNHEIMER CHARITABLE TRUST, FIRST FIDELITY BANK, N.A., TRUSTEE, FORMERLY FIRST NATIONAL STATE BANK OF NEW JERSEY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 12, 1989.

Attorney(s) appearing for the Case

Catherine Romania Mattera, for the petitioner.

Barbara Fazekas, for the respondent.

RAUM, Judge:

The Commissioner determined that petitioner, taxable as a private foundation, is liable for the 10-percent private foundation excise tax under section 4945(a)(1)1 in the amounts of $42,184 in 1981, $41,205 in 1982, and $26,173 in 1983, in respect of grants which it made to two other private foundations. The issue is whether such grants were "taxable expenditures" under section...

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