Legal Opinion

Foundation of Human Understanding v. Commissioner

United States Tax Court

Decided May 19, 1987No. Docket No. 10431-83XPublished

Petitioner was formed to spread the religious teachings of its founder through a broadcasting and publishing ministry. In addition to its broadcasting and publishing efforts, petitioner regularly conducts religious services at two locations where followers of petitioner's founder congregate.

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Petitioner was formed to spread the religious teachings of its founder through a broadcasting and publishing ministry. In addition to its broadcasting and publishing efforts, petitioner regularly conducts religious services at two locations where followers of petitioner's founder congregate. Petitioner requested a ruling that it was a nonprivate foundation as a church within the meaning of secs. 509(a)(1) and 170(b)(1)(A)(i), I.R.C. 1954. Respondent determined that petitioner was a nonprivate foundation as a publicly supported organization under secs. 509(a)(1) and 170(b)(1)(A)(vi), I.R.C.…

1Opinion of the Court

Foundation of Human Understanding, Petitioner v. Commissioner of Internal Revenue, Respondent

Foundation of Human Understanding v. Commissioner

Docket No. 10431-83X

United States Tax Court

88 T.C. 1341; 1987 U.S. Tax Ct. LEXIS 75; 88 T.C. No. 75;

May 19, 1987. May 19, 1987, Filed

Decision will be entered for the petitioner.

Petitioner was formed to spread the religious teachings of its founder through a broadcasting and publishing ministry. In addition to its broadcasting and publishing efforts, petitioner regularly conducts religious services at two locations where followers of petitioner's founder…

Also in this document: Concurrence; Dissent · Simpson; Dissent · Chabot; Dissent · Williams.

2Cases cited32 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Bob Jones University v. SimonSupreme Court of the United States · 1974
  3. Alexander v. "Americans United" Inc.Supreme Court of the United States · 1974
  4. United States v. WurtsSupreme Court of the United States · 1938
  5. Davis v. CommissionerUnited States Tax Court · 1983

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