Burwell v. Commissioner
United States Tax Court
Petitioners formed charter congregations of the Universal Life Church, Inc., Modesto, opened bank accounts in the name of Universal Life Church, Inc., of which they were sole signatories, and paid various living and personal expenses from such accounts. Held: 1. Petitioners did not make gifts to a tax-exempt organization when they transferred funds into the bank accounts.
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Petitioners formed charter congregations of the Universal Life Church, Inc., Modesto, opened bank accounts in the name of Universal Life Church, Inc., of which they were sole signatories, and paid various living and personal expenses from such accounts. Held: 1. Petitioners did not make gifts to a tax-exempt organization when they transferred funds into the bank accounts. Held, further, petitioners' charter congregations were not such an integral part of Universal Life Church, Inc., Modesto, as to also be tax-exempt at the time of the fund transfer. 2. Petitioners are liable for additions to…
1Opinion of the Court
OPINION
FEATHERSTON, Judge-.
These consolidated cases were assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section 7456(d) (redesignated sec. 7443A(b) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180 and 181.1 The Court agrees with and adopts her opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
BUCKLEY, Special Trial Judge:
Docket No. 22943-83, David C. and Betty B. Burwell, was tried first; subsequently, its record was incorporated by reference into the record in docket No. 9585-84, James L. Harrold. The…
2Cases cited29 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
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3Cited by25 opinions
- Allen v. CommissionerUnited States Tax Court · 1989
- Universal Life Church, Inc. v. United StatesUnited States Court of Claims · 1987
- Charles Burke v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Dew v. CommissionerUnited States Tax Court · 1988
- Hopcus v. CommissionerUnited States Tax Court · 1988
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