Opinion
29876-21X
07-19-2022
AEGIS FOR DREAMS FOUNDATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan Chief Judge
On July 14, 2022, the parties filed a Proposed Stipulated Decision for the Court's consideration. However, the Court notes that the caption on the proposed decision document does not match the caption of this case. Consequently, the Court is unable to process the parties' Proposed Stipulated Decision.
In view of the foregoing, to give effect to the agreement of the parties in this case, and for cause, it is
ORDERED that the parties' Proposed Stipulated Decision is recharacterized as the parties' Settlement Stipulation. Taking into account the basis for settlement reached between the parties, as reflected in that document, it is further
DECLARED, ADJUDGED, and DECIDED that, as of July 1, 2022, petitioner is qualified as an organization described in I.R.C. section 501(c)(3) and is exempt from taxation under I.R.C. section 501(a);
That, as of July 1, 2022, petitioner is a non-private foundation within the meaning of I.R.C. section 509(a)(1) and I.R.C. section 170(b)(1)(A)(vi); and
That, as of July 1, 2022, petitioner is an organization described in I.R.C. section 170(c)(2).