Church in Boston v. Commissioner
United States Tax Court
Petitioner was organized as a religious organization. It used substantial portions of its receipts for making grants of cash to individuals, including its officers, based upon no fixed criteria with no provision for repayment. Held, in a declaratory judgment action under sec. 7428(a), I.R.C. 1954, petitioner has not been operated exclusively for tax-exempt purposes and cannot qualify for exemption from taxation under secs. 501(a) and 501(c)(3), I.R.C. 1954.
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined that petitioner does not qualify for exemption from Federal income tax under section 501(a), Internal Revenue Code of 1954,1 as an organization described in section 501(c)(3). Petitioner has challenged respondent’s determination by invoking the jurisdiction of this Court for a declaratory judgment pursuant to section 7428. The issue for our decision is whether petitioner satisfies the operational requirements as set forth in the regulations under section 501(c)(3). Sec. 1.501(c)(3)-l(c), Income Tax Regs.
This proceeding was submitted under Rule…
2Cases cited11 opinions
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