USTC Cases, Lapham Foundation, Inc., Petitioner-Appellant v. Commissioner
of Internal Revenue, Respondent-Appellee., U.S. Court of Appeals, Sixth
Circuit, 2004-2 U.S.T.C. ¶50,420, (Nov. 18, 2004)
Lapham Foundation ... Circuit Judges; COOK, District Judge. *-
OPINION
MARTHA CRAIG DAUGHTREY, Circuit Judge . The petitioner, Lapham Foundation, Inc., appeals from a Tax Court
judgment classifying it as a private foundation under ... address the issue
raised under §509(a)(3)(C).
FACTUAL AND PROCEDURAL BACKGROUND
Lapham Foundation, Inc. (the Foundation), is a Michigan non-profit corporation, organized under its articles "to
operate