Contemporary Mission, Inc. v. United States

Under 28 U.S.C. § 1507 and 26 U.S.C. § 7428(a), plaintiff Contemporary Mission, Inc. seeks a declaratory judgment that it qualifies as an exempt organization under 26 U.S.C. § 501(c)(3) (charitable, religious, etc. organization "no part of the net earnings of which inures to the benefit of any private shareholder or individual”)- In September 1979, the Internal Revenue Service determined that plaintiff did not so qualify. The Service found that, although plaintiff was a pious nonprofit society composed of a small number of Roman Catholic priests, in fact it carried on a direct mail marketing…