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Abstract: 

In Loren E. Parks v. Comm’r, the Tax Court found a private foundation liable for excise taxes on expenditures made to air politically oriented radio ads. Representatives of the IRS have described the case as “an important victory,” with “important follow-on attributes.” Although only two of the foundation’s ads referred to a piece of legislation by name, and although the foundation argued that the ads were “educational,” the court found that all but one ad gave rise to taxable expenditures. The Loren E. Parks opinion is worth a closer look, because it includes a rare in-depth examination of the text of various communications and the multi-level analysis that the court used to reach its holding.

Keywords: Taxability of Lobbying Expenditures; non-partisan analysis; Loren E. Parks v. Comm’r

Affiliations:  1: Strasburger & Price, LLP.