Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Series

PDF

2000

All Faculty Scholarship

Tax Law

Taxation-Federal Estate and Gift

Articles 1 - 1 of 1

Full-Text Articles in Law

A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody Mar 2000

A Taxing Time For The Bishop Estate: What Is The I.R.S. Role In Charity Governance?, Evelyn Brody

All Faculty Scholarship

This piece, included in the University of Hawaii Law Review's symposium issue on the Bishop Estate, explores the relationship between the new intermediate sanctions law and the IRS's power to revoke tax exemption under ยง 501(c)(3). Inspired by the storied setting, I indulge in a fantasy: This article pretends that the IRS revoked the Estate's exemption, and takes the form of the Tax Court declaratory judgment opinion. I reluctantly 'rule' that exemption was not appropriate, because State enforcement action against the trustees was proceeding. (However, this forum allows me to hedge my argument by producing two ...