Universal Life Church, Inc. (Full Circle) v. Commissioner
United States Tax Court
Petitioner Full Circle instituted this action for declaratory judgment pursuant to sec. 7428, I.R.C. 1954. Full Circle received a charter from the Universal Life Church, Modesto, Inc. (ULC). Full Circle claimed "church" status relying on the exempt status of the ULC. Petitioner did not file an application for exempt status with the Internal Revenue Service.
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Petitioner Full Circle instituted this action for declaratory judgment pursuant to sec. 7428, I.R.C. 1954. Full Circle received a charter from the Universal Life Church, Modesto, Inc. (ULC). Full Circle claimed "church" status relying on the exempt status of the ULC. Petitioner did not file an application for exempt status with the Internal Revenue Service. After an examination of Full Circle, respondent issued an adverse determination letter that Full Circle was not an exempt organization within the meaning of sec. 501(c)(3). Held, that respondent had authority to examine Full Circle and…
1Opinion of the Court
Universal Life Church, Inc. (Full Circle), Petitioner v. Commissioner of Internal Revenue, Respondent
Universal Life Church, Inc. (Full Circle) v. Commissioner
Docket No. 21925-81X
United States Tax Court
83 T.C. 292; 1984 U.S. Tax Ct. LEXIS 34; 83 T.C. No. 19;
August 30, 1984. August 30, 1984, Filed
Decision will be entered for the respondent.
Petitioner Full Circle instituted this action for declaratory judgment pursuant to sec. 7428, I.R.C. 1954. Full Circle received a charter from the Universal Life Church, Modesto, Inc. (ULC). Full Circle claimed "church" status relying on the exempt status of…
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