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BONNER v. COMMISSIONER OF INTERNAL REVENUE

No. 84-1584.

474 U.S. 923 (1985)

BONNER ET AL. v. COMMISSIONER OF INTERNAL REVENUE

Supreme Court of United States.

October 21, 1985.

Certiorari denied.

JUSTICE O'CONNOR, with whom JUSTICE BLACKMUN and JUSTICE POWELL join, dissenting.

Section 4945 of the Internal Revenue Code, 26 U.S.C. § 4945, imposes a substantial excise tax on noncharitable expenditures by a private foundation. Transfers remain taxable under this section only as long as the organization retains its foundation status. Upon the termination of that status, tax liability is assessed pursuant to § 507(c). Petitioners...

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