Musk’s Legal Expert Says OpenAI Foundation Should Have “A Lot More” Than $200 Billion
Musk's lawsuit just escalated. A Columbia Law dean testified OpenAI's nonprofit structure violates tax law — with $200B+ at stake.

Why it matters
Musk's legal challenge to OpenAI's nonprofit-to-for-profit transition is entering substantive testimony phase with expert validation of structural violations. This could reshape how AI companies organize their governance and cap tables.
The key facts
10 to knowDavid Schizer (Columbia Law dean 2004-2014, tax/nonprofit law expert) testified for Musk's case
Testimony claims OpenAI foundation should hold significantly more than $200B in assets
Core allegation: OpenAI acted inconsistently with nonprofit customs and tax law compliance
Case centers on OpenAI's for-profit subsidiary structure and nonprofit governance transition
Published May 8, 2026 — ongoing litigation with escalating expert testimony
David Schizer (former Columbia Law dean, tax/nonprofit specialist) testifying for Musk
Testimony centers on OpenAI's alleged deviation from nonprofit customs
$200 billion valuation referenced in dispute over foundation asset adequacy
Lawsuit focuses on structural inconsistency between nonprofit status and for-profit operations
May 2026 hearing date
Go to the source
The Informationtheinformation.com
Publisher excerpt: Elon Musk’s team called the former dean of Columbia Law School to testify Thursday in his lawsuit against OpenAI that the ChatGPT maker acted in several ways inconsistent with nonprofit customs. David Schizer, who served as dean from 2004 to 2014 and specializes in tax and nonprofit law, ...
