Graham v. Commissioner
United States Tax Court
Held: The payments made by petitioners to the various churches of Scientology were not charitable contributions within the meaning of sec. 170(c), I.R.C. 1954. The remittances were made with the expectation of receiving a benefit, and such benefit was received. Thus, the transfers were in reality a quid pro quo. Held, further, denial of the claimed deductions did not violate any of petitioners' constitutional rights.
1Opinion of the Court
Sterrett, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Docket TYE Date of No. Petitioner Dec. 31— Deficiency deficiency notice
5837-76 Katherine Jean Graham2 1972 $316.24 Apr. 7, 1976
Docket No. Petitioner TYE Date of Dec. 31— Deficiency deficiency notice
9384-79 Richard M. Hermann 1975 $803.00 Apr. 4, 1979
374-80 David Forbes Maynard 1977 643.00 Nov. 14, 1979
The issues before the Court are: (1) Whether payments made by petitioners to the various churches of Scientology3 were deductible charitable contributions, and (2)…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- McGowan v. MarylandSupreme Court of the United States · 1961
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Prince v. MassachusettsSupreme Court of the United States · 1944
- Reynolds v. United StatesSupreme Court of the United States · 1879
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3Cited by27 opinions
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Elrod v. CommissionerUnited States Tax Court · 1986
- Graham v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- Robert L. Hernandez v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1987
- Arlen v. Comm'rUnited States Tax Court · 1967
22 more not listed; retrieve them via the Exa API.