Universal Life Church, Inc. v. United States

OPINION ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

PHILIP R. MILLER, Judge:

This is a suit for a declaratory judgment that plaintiff is entitled to exemption from federal income tax pursuant to § 501(c) of the Internal Revenue Code of 1954 (the Code or I.R.C.), as a corporation organized and operated exclusively for religious purposes, no part of the net earnings of which inures to the benefit of any private individual. Jurisdiction of such a suit is conferred on this court by I.R.C. § 7428 and 28 U.S.C. § 1507.

I

Plaintiff alleges that it is a California non-profit religious corporation duly…