
Ononuju v. Commissioner (T.C. Memo. 2021-94)
On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Ononuju v. Commissioner (T.C. Memo. 2021-94). The primary issue presented in Ononuju was whether the petitioner was liable for excise tax pursuant to IRC § 4958 as a “disqualified person” who engages in an “excess benefit transaction” with a tax-exempt charity. Background to Assessment The IRS determined that the petitioner was a disqualified person with respect to American Medical Missionary