First Libertarian Church v. Commissioner
United States Tax Court
Petitioner First Libertarian Church claimed exemption from tax under sec. 501(c)(3), I.R.C. 1954, as a religious organization. After denial of exemption by respondent, the church petitioned this Court under sec. 7428. Petitioner's primary activities were to hold meetings before supper, sponsor a supper club, and publish a newsletter.
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Petitioner First Libertarian Church claimed exemption from tax under sec. 501(c)(3), I.R.C. 1954, as a religious organization. After denial of exemption by respondent, the church petitioned this Court under sec. 7428. Petitioner's primary activities were to hold meetings before supper, sponsor a supper club, and publish a newsletter. Held: Petitioner failed to show that it successfully segregated the clearly social and political aspects of its supper club meetings and its publication from its purpose to further the doctrine of ethical egoism. As the church operated for social and political…
1Opinion of the Court
OPINION
Sterrett, Judge:
Respondent determined that petitioner is not entitled to exemption from Federal income tax as an organization described in section 501(c)(3), I.R.C. 1954. On January 26, 1975, petitioner filed an “Application for Recognition of Exemption” under section 501(c)(3). By letter dated March 9, 1976, respondent made a preliminary determination denying recognition of the desired exempt status under section 501(c)(3). Petitioner protested that denial but, after further proceedings, received a final adverse determination by letter dated November 18, 1977, in which respondent…
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