Legal Opinion

World Family Corp. v. Commissioner

United States Tax Court

Decided December 14, 1983No. Docket No. 28947-81XPublishedCited by 23 opinions

WFC seeks a declaratory judgment that it is entitled to tax-exempt status as an organization described in sec. 501(c)(3), I.R.C. 1954. WFC's primary activity will be to provide financial assistance to missionaries of the Church of Jesus Christ of Latter-Day Saints. As a subordinate activity, WFC will fund scientific research into new energy sources and conservation measures.

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WFC seeks a declaratory judgment that it is entitled to tax-exempt status as an organization described in sec. 501(c)(3), I.R.C. 1954. WFC's primary activity will be to provide financial assistance to missionaries of the Church of Jesus Christ of Latter-Day Saints. As a subordinate activity, WFC will fund scientific research into new energy sources and conservation measures. WFC plans to offer commissions of up to 20 percent to fund raisers who procure contributions for the organization. Held: WFC is operated exclusively for religious and charitable purposes; its proposed scientific research…

1Opinion of the Court

OPINION

Nims, Judge:

Petitioner brought this action for a declaratory judgment pursuant to section 74281 and Rule 211 on the ground that respondent had failed to determine whether petitioner qualifies as an organization exempt from taxation under sections 501(a) and 501(c)(3). The issues presented are whether petitioner is operated exclusively for religious, charitable, scientific, or other exempt purposes and whether part of petitioner’s net earnings inures to the benefit of private individuals.

This case is submitted for decision on the stipulated administrative record pursuant to Rule 122.…

2Cases cited16 opinions

  1. Bartels v. BirminghamSupreme Court of the United States · 1947
  2. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
  3. Church in Boston v. CommissionerUnited States Tax Court · 1978
  4. The Founding Church of Scientology v. The United StatesUnited States Court of Claims · 1969
  5. Copyright Clearance Center, Inc. v. CommissionerUnited States Tax Court · 1982

11 more not listed; retrieve them via the Exa API.

3Cited by23 opinions

  1. Nationalist Movement v. CommissionerUnited States Tax Court · 1994
  2. Friendship Village of Greater Milwaukee, Inc. v. City of MilwaukeeCourt of Appeals of Wisconsin · 1993
  3. Manning Ass'n v. CommissionerUnited States Tax Court · 1989
  4. Easter House v. United StatesUnited States Court of Claims · 1987
  5. La Verdad v. CommissionerUnited States Tax Court · 1984

18 more not listed; retrieve them via the Exa API.

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