Legal Opinion

Church of Scientology v. Commissioner

United States Tax Court

Decided September 24, 1984No. Docket No. 3352-78Published

Petitioner, a Church incorporated in the State of California, was granted tax-exempt status in 1957 under sec. 501(c)(3), I.R.C. 1954. In 1967, respondent sent petitioner a letter revoking its exemption following an audit of petitioner's records which was in part sparked by litigation involving the tax-exempt status of an affiliated Church of Scientology.

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Petitioner, a Church incorporated in the State of California, was granted tax-exempt status in 1957 under sec. 501(c)(3), I.R.C. 1954. In 1967, respondent sent petitioner a letter revoking its exemption following an audit of petitioner's records which was in part sparked by litigation involving the tax-exempt status of an affiliated Church of Scientology. Subsequent to issuing the letter of revocation, respondent conducted several audits of petitioner's records for various tax years and also reviewed the tax status of several affiliated churches. Petitioner was also investigated by several…

1Opinion of the Court

Church of Scientology of California, Petitioner v. Commissioner Of Internal Revenue, Respondent

Church of Scientology v. Commissioner

Docket No. 3352-78

United States Tax Court

83 T.C. 381; 1984 U.S. Tax Ct. LEXIS 30; 83 T.C. No. 25;

September 24, 1984September 24, 1984, Filed

Decision will be entered under Rule 155.

Petitioner, a Church incorporated in the State of California, was granted tax-exempt status in 1957 under sec. 501(c)(3), I.R.C. 1954. In 1967, respondent sent petitioner a letter revoking its exemption following an audit of petitioner's records which was in part sparked by litigation…

2Cases cited194 opinions

  1. Jackson v. VirginiaSupreme Court of the United States · 1979
  2. Coolidge v. New HampshireSupreme Court of the United States · 1971
  3. Welch v. HelveringSupreme Court of the United States · 1933
  4. Mt. Healthy City School District Board of Education v. DoyleSupreme Court of the United States · 1977
  5. Santosky v. KramerSupreme Court of the United States · 1982

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