Junaluska Assembly Housing, Inc. v. Commissioner
United States Tax Court
P seeks a declaratory judgment that it is an organization described in sec. 501(c)(3), I.R.C. 1954, that is not a private foundation pursuant to secs. 509(a)(1) and 509(a)(3). P, an auxiliary of the United Methodist Church, was formed to contract for the construction of housing at Lake Junaluska, a conference and retreat center of the Southeast Jurisdiction of the United Methodist Church.
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P seeks a declaratory judgment that it is an organization described in sec. 501(c)(3), I.R.C. 1954, that is not a private foundation pursuant to secs. 509(a)(1) and 509(a)(3). P, an auxiliary of the United Methodist Church, was formed to contract for the construction of housing at Lake Junaluska, a conference and retreat center of the Southeast Jurisdiction of the United Methodist Church. P is owned and controlled by Lake Junaluska Assembly, Inc., a church and auxiliary of the United Methodist Church, which owns the assembly grounds and conducts the religious programs and activities at the…
1Opinion of the Court
OPINION
WILLIAMS, Judge:*
The Commissioner determined that petitioner does not qualify for exemption from Federal income taxation under section 501(a)1 as an organization described in section 501(c)(3) and that petitioner is not a “church” within the meaning of section 170(b)(l)(A)(i) for purposes of determining its status as a private foundation under section 509(a)(1). Pursuant to section 7428, petitioner seeks a declaratory judgment of this Court that it is an exempt organization described in section 501(c)(3) and that it is not a private foundation under both section 509(a)(1) and section…
2Cases cited10 opinions
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